Insider management

Insider Regulation

In its insider management, Sunborn International Plc complies with the applicable legislation and regulatory guidance, including the EU Market Abuse Regulation ((EU) No. 596/2014, as amended), the Finnish Limited Liability Companies Act (624/2006, as amended), the Finnish Securities Markets Act (746/2012, as amended), the Finnish Penal Code (39/1889, as amended), and any applicable rules issued by Nasdaq Helsinki Ltd. In addition, the company follows relevant regulations and guidelines issued by the European Securities and Markets Authority (ESMA) and the Finnish Financial Supervisory Authority (FIN-FSA). Sunborn International's insider management is further governed by its Insider Policy, as approved by the Company’s Board of Directors.

Insider Lists

Sunborn International maintains project-specific insider lists to record individuals with access to inside information. These lists are created whenever confidential information is linked to a particular project or event and are updated as needed. Individuals are informed of their inclusion, their responsibilities under MAR, and the prohibition on unlawful disclosure or use of such information. Insider lists are retained for a minimum of five years to ensure transparency and traceability.

Supervision

The CEO is responsible for the overall implementation and supervision of the Insider Policy. Day-to-day oversight, including the maintenance of insider lists and internal communication, is handled by the company secretary. Together, they ensure that the handling of inside information complies with legal obligations and internal procedures. They also provide training and guidance to employees to maintain a high level of awareness and compliance.

Managers and Managers’ Transactions

In Sunborn International Plc, the Board of Directors, CEO and members of the Management Team have been defined as managers in accordance with the EU Market Abuse Regulation (MAR). Managers and their closely associated persons are obliged to notify Sunborn International and the FIN-FSA, once annual transaction thresholds are exceeded. The transactions of Sunborn International Plc's managers and their closely associated persons are disclosed in accordance with MAR.

Closed Period

Sunborn International Plc’s managers are subject to a closed period of 30 calendar days prior to the publication of the company’s financial statements release and half-year report. The company applies the same 30-day closed period to individuals who participate in the preparation of Sunborn International’s financial reporting. During this time, the individuals covered by the restriction are prohibited from trading in Sunborn International’s shares or other financial instruments issued by the company.