Insider administration

2.1 Contact persons

The Company’s IR Manager acts as the person in charge of insider issues. The Company’s person in charge of insider issues is responsible, on behalf of the Company, for internal communication on insider issues, training on insider issues, and for monitoring compliance with this policy. The Company’s person in charge of insider issues is also responsible for drawing up and maintaining insider lists, for communication relating to trading restrictions, and for receiving and disclosing transaction notifications. The Company’s Chief Financial Officer, or such other person as the person in charge of insider issues designates from time to time, acts as the deputy for the Company’s person in charge of insider issues.

2.2 Duty to provide training and information

The Company ensures that insiders recognise their position and its implications. Training and information for insiders is timed to coincide with the commencement of employment, the assumption of a new insider position, and changes in legislation, regulatory guidance, Nasdaq’s rules, or the Company’s own guidelines.

Every employee and insider of Robit is at all times personally responsible for complying with the applicable laws, regulations and guidelines relating to inside information. Every employee of Robit must assess for themselves, on an ongoing basis, whether information in their possession constitutes inside information and must comply with the relevant regulations to the applicable extent. This obligation applies at all times, regardless of whether the person has been entered in an insider list or has obtained inside information, for example, by accident.

2.3 Supervision

The Company has organized regular supervision of the trading and notification obligations of persons on the Company’s insider list as well as persons discharging managerial responsibilities and their closely associated persons.

The Finnish Financial Supervisory Authority supervises the prohibited use of inside information, the drawing up and maintenance of insider lists, compliance by persons discharging managerial responsibilities with the trading restriction, and the notification obligation and disclosure of transactions of persons discharging managerial responsibilities and their closely associated persons.

The misuse of inside information may, under the Finnish Criminal Code (39/1889), result in a fine or imprisonment for up to four years, and the unlawful disclosure of inside information may result in a fine or imprisonment for up to two years. Under the Securities Markets Act, the prohibited use or unlawful disclosure of inside information may result in an administrative sanction fee imposed by the Finnish Financial Supervisory Authority.

If a person in an employment or service relationship with Robit breaches the instructions or requirements set out in this document, Robit may, depending on the nature of the breach, be entitled to issue the person a warning or to terminate their employment. Robit may also, at its discretion, be entitled to terminate the person’s employment or other contract with immediate effect.

The Company has a whistleblowing reporting channel through which both the Company’s personnel and external parties can report suspected misconduct. Reportable suspicions may concern the Company’s personnel, a customer, a supplier or another stakeholder. The use of the whistleblowing reporting channel at the Company reduces the likelihood of misconduct and promotes the Company’s ethically sustainable business operations. Reports and suspicions are submitted through the WhistleB reporting channel maintained by an independent and impartial third party: https://report.whistleb.com/en/robitgroup. Reports are handled anonymously.

Robit informs the public as soon as possible of inside information that directly concerns Robit or its financial instruments. The disclosure of inside information is decided by the Company’s CEO or the Chairman of the Company’s Board of Directors alone, or by the Company’s CFO and the person in charge of insider issues jointly.

The Company may, exceptionally, decide to delay the disclosure of inside information, provided that all of the following conditions are met:

1. immediate disclosure of the inside information would be likely to prejudice the legitimate interests of the Company;

2. the Inside Information is not in contrast with the latest public announcement or other type of communication by the Company on the same matter to which the Inside Information refers to¹; and

3. the Company is able to ensure the confidentiality of the inside information.

The decision on any delay of disclosure of inside information and on the establishment of an insider list is made by the Chairman of the Company’s Board of Directors together with the Board, and, in urgent cases, by the Company’s CEO or the Chairman of the Company’s Board of Directors. The decision on whether the conditions for delaying disclosure of inside information are met is always based on a careful assessment. The Chairman of the Board together with the Board, and the CEO, continuously monitor whether the conditions for delay continue to be met, so that the Company is prepared to disclose the inside information immediately if the conditions for delay are no longer met. The Company’s person in charge of insider issues is responsible for documenting and retaining the assessment and the decision to delay. Information on the decision to delay must be submitted to the Finnish Financial Supervisory Authority after the information has been disclosed.

No decision to delay is made regarding interim steps of a protracted process. Inside information relating to interim steps of a protracted process is, as a rule, not disclosed; instead, in protracted processes only the final event or the final circumstances are disclosed by way of a stock exchange release.² The final circumstances or the final event are disclosed as soon as possible after they occur.

The Company must always ensure the confidentiality of inside information until the information in question has been disclosed. If inside information has not been disclosed, and the confidentiality of that information can no longer be ensured, the Company must disclose the information to the public as soon as possible. The same requirement applies both to inside information relating to interim steps of a protracted process and to situations where the disclosure of inside information has been delayed.

¹ In assessing whether the inside information to be delayed is inconsistent with previous communication, account is taken of Annex II of Commission Delegated Regulation (EU) 2026/789, issued under Article 17(12) of MAR.

² In assessing the final events or final circumstances of a protracted process and the timing of their disclosure, account is taken of Annex I of Commission Delegated Regulation (EU) 2026/789, issued under Article 17(12) of MAR.

If the Company decides to delay the disclosure of inside information or holds inside information relating to interim steps of a protracted process, it shall immediately establish a project-specific list concerning that inside information. Inside information held by the Company typically relates to an identifiable set of measures or arrangement that is being confidentially prepared by the Company and that, if realised, would be likely to have a significant effect on the price of the Company’s financial instruments or related derivatives (a project).

Robit maintains a project-specific insider list for such projects as constitute inside information. Every person who receives inside information relating to a project is entered on the project-specific insider list without delay. The Company has assessed that it does not have any permanent insiders in respect of whom it would be necessary to maintain a separate permanent section of the insider list.

A person entered on the insider list is notified in writing of their inclusion on the insider list, of the obligations arising from this, and of the sanctions applicable to insider dealing and to the unlawful disclosure of inside information.

The Company has established on its website a page entitled Transactions of Managers, which contains the information and guidance that persons discharging managerial responsibilities and their closely associated persons need in order to make and submit transaction notifications to the Company and to the Finnish Financial Supervisory Authority.

Robit discloses the transaction notifications it receives by way of a stock exchange release without delay, or at the latest within two business days of the Company’s receipt of the notification from the person discharging managerial responsibilities or their closely associated person. The Company does not separately verify the accuracy of the notifications it receives.

For the purposes of Article 3(1)(25) of MAR, the Company’s persons discharging managerial responsibilities are:

1. a member and deputy member of Robit’s Board of Directors;

2. Robit’s CEO and their deputy; and

3. members of Robit’s management team.

For the purposes of Article 3(1)(26) of MAR, persons closely associated with persons discharging managerial responsibilities are:

1. a spouse or a partner considered equivalent to a spouse under national law;

2. a dependent child;

3. a relative who has shared the same household for at least one year on the date of the transaction concerned;

4. a legal person, trust or partnership, the managerial responsibilities of which are discharged by a person discharging managerial responsibilities or by a person referred to in items 1, 2 or 3 above, or which is directly or indirectly controlled by such a person, or which is set up for the benefit of such a person, or the economic interests of which are substantially equivalent to those of such a person.

The entities referred to in item 4 above are entities in which the person concerned participates in, or has influence over, the entity’s decision-making on transactions in Robit’s financial instruments.

Robit complies with the MAR closed period applicable to persons discharging managerial responsibilities. The Company may grant an exception from the said trading prohibition in the situations permitted by Article 19(12) of MAR. The decision on an exception is made jointly by the Company’s CEO and CFO.

Robit has additionally separately defined certain persons in its informational core who participate in the preparation of financial reports, or who have access to information relating thereto or to other sensitive information concerning the Company. Robit has designated these persons as persons covered by the trading restriction, other than persons discharging managerial responsibilities. Persons covered by the trading restriction include, among others, persons participating in the preparation of financial reports, the Company’s auditor, the management’s assistant, other persons participating in the work of the Board of Directors who are not Board members such as the secretary to the Board, and certain persons in the informational core who, on the basis of the duties they perform, have access to sensitive information concerning the Company. Persons designated by the Company from time to time may not trade or carry out transactions for their own account or for the account of a third party, directly or indirectly, relating to Robit’s shares or debt instruments or related derivatives or other financial instruments, during the closed period. This period begins 30 days before the disclosure of the financial statements release, the interim reports and any other financial reviews, and ends upon their disclosure. The Company may grant an exception from the said trading prohibition in corresponding situations under Article 19(12) of MAR. The decision on an exception is made jointly by the Company’s CEO and CFO.

The Company may also impose other trading restrictions.

Irrespective of the trading restrictions, transactions in the Company’s financial instruments are always prohibited where the person intending to trade is in possession of inside information relating to the Company or its financial instruments.

Persons who occasionally or regularly receive inside information concerning Robit may carry out transactions in Robit’s financial instruments, notwithstanding any inside information they may hold, by establishing a trading programme that meets the applicable regulatory requirements. Under a trading programme, a person gives another party a mandate to carry out transactions independently, within the scope of the mandate given. However, a trading programme must be established at a time when the person does not possess inside information and is not subject to a trading restriction.