Insider Trading and Flagging Announcements

People with Access to Insider Information

Companies listed on the AktieTorget exchange do not need to report the names of people with access to insider information to the Swedish Financial Supervisory Authority. Instead, such information shall be reported to AktieTorget. The following regulations apply:

• People considered to have insider information include:
  1. Members of the board and alternates to the board in the Company and its parent company,
  2. The CEO and Vice President of the Company and its parent company,
  3. The CPA and alternate CPA of the Company and its parent company,
  4. Anyone who holds another senior management position or performs other high level duties on a regular basis for the Company and its parent company if the position or task can under normal circumstances be assumed to provide access to non-public information of such a nature that it could influence the price of the Company's shares,
  5. Officers or consultants according to points 1-3 or other senior managers in a subsidiary, if these people can under normal circumstances be assumed to have access to non-public information of such a nature that it could influence the price of the Company's shares,
  6. Anyone who owns shares in the Company equivalent to at least 10 percent of the total share capital or who controls 10 percent of the votes in the Company or owns this amount of shares or controls this amount of votes together with relatives or a legal entity owned by relatives, if he/she can be assumed to have access to non-public information of such a nature that it could influence the price of the shares in the Company.
• These persons and their holdings are reported to AktieTorget, which posts the information on their website.
• The Company informs those with access to insider information that all business transactions they execute with the shares of the Company shall be reported to AktieTorget within five working days. This information can be reported directly by the individual or through the Company. The notification will include information about the current business transaction and the number of shares held after the transaction. AktieTorget will publish the holdings of the person with access to non-public information and the change in holdings after the notification.
• Persons in a position of insight listed in 1 – 3 above and their close relations may not trade with the Company's shares during the thirty days prior to an announcement regarding the annual accounts, interim reports, quarterly reports or quarterly management reports being published, including the date of publication.

Flagging Announcements

The Company shall strive to provide information to AktieTorget about certain transactions of larger shareholders who are not privy to insider information. The following is in force:

Larger shareholders are considered to be those people who own shares in the Company equivalent to at least 10 percent of the total share capital of the Company or who control 10 percent of the total votes or who own an equivalent number of shares or control an equivalent number of votes together with a relative or legal entity, which is owned by a relative.

Larger shareholders shall provide information to AktieTorget about buying or selling of shares that results in shareholdings that exceed one of the following limits: 10, 20, 30, 50, 66.7 or 90 percent of total share capital.

The notification and verification of the notification are carried out and managed in the same way as for the insider information notification.