Disclosure policy

Reports and releases subject to the regular disclosure obligation are approved by the Board of Directors. In addition, the Board of Directors approves significant stock exchange releases, such as the release announcing the appointment of the CEO. Releases relating to the disclosure of inside information are approved by the Board of Directors, or, in particularly urgent cases, jointly by the Chairman of the Board and the CEO, and releases relating to other stock exchange disclosures are approved by the CEO alone or, as their deputy, the CFO. The CEO or other members of the Company’s management do not comment on matters concerning the Company’s Board of Directors. The Board of Directors is represented by the Chairman of the Board.

Listed companies are subject to both a regular and an ongoing disclosure obligation. In addition, the Company is subject to other disclosure obligations arising from applicable laws and regulations.

3.1 Regular, ongoing and other disclosure obligations

Regular disclosure obligation:

The regular disclosure obligation includes reporting of the financial statements and interim reports. Robit publishes financial reviews in the form of interim reports on a quarterly basis, and, before the start of a new financial year, discloses a financial calendar setting out the planned publication dates of the financial statements release and the interim reports for the following financial year. The financial calendar is also available on the Company’s website.

Ongoing disclosure obligation:

Robit discloses, by way of a stock exchange release, as soon as possible, information on significant and precise decisions, matters and events directly concerning itself which are assessed to be such that their disclosure would be likely to have a significant effect on the price of Robit’s share or any other financial instruments or related financial derivatives (a “Financial Instrument”) (“Inside Information”).

Inside Information is assessed to be precise if it indicates a set of circumstances which exists or which may reasonably be expected to come into existence, or an event which has occurred or which may reasonably be expected to occur, where it is specific enough to enable a conclusion to be drawn as to the possible effect of that set of circumstances or event on the price of Robit’s Financial Instrument.

Information that would be likely to have a significant effect on the price of Robit’s Financial Instrument if it were disclosed refers to information that a reasonable investor would be likely to use as part of the basis of their investment decisions.

Information that may constitute Inside Information includes, among other things:

• changes in the Company’s management;

• future outlook and profit warnings;

• significant investments, loan arrangements and corporate acquisitions;

• significant changes in the business environment;

• a significant reorientation of business operations or a new cooperation arrangement;

• information on a share issue, a takeover or redemption bid, or another change concerning the Company’s Financial Instruments, such as the combination or division of Financial Instruments or share series; and

• the commencement of a significant legal proceeding or a decision issued therein, and a significant decision by an authority.

Robit’s Board of Directors, or, in urgent situations, the CEO or the Chairman of the Board, assesses whether information that has arisen constitutes Inside Information.

Other disclosure obligation:

The Company’s other disclosure obligation concerns, among other things, notices convening the general meeting and proposals made to the general meeting by the Board of Directors or another party, share issuances, changes in the Company’s Board of Directors or management, a change of auditor, share-based incentive schemes, transactions between the Company and its related parties, and the acquisition or disposal of own shares.

The Company discloses information on the above-mentioned matters as soon as possible.

3.2 Disclosure of Inside Information in 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. With respect to such protracted processes, the Company must ensure that the information remains confidential until disclosure and must assess the need to disclose the information on that basis. If the confidentiality of Inside Information relating to interim steps of a protracted process can no longer be ensured, that Inside Information must be disclosed to the public as soon as possible.

No decision to delay disclosure is made in respect of interim steps of a protracted process, and no information on them is therefore submitted to the Finnish Financial Supervisory Authority. When assessing the final events or final circumstances of a protracted process and the disclosure timing, Commission Delegated Regulation (EU) 2026/789 Annex I, issued under Article 17(12) of MAR, is taken into account.

3.3 Delay of disclosure of Inside Information in certain situations

Robit discloses Inside Information directly concerning itself or its Financial Instrument as soon as possible. The Company may, however, 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 Company’s legitimate interests;

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 to; and

3. the Company is able to ensure the confidentiality of the Inside Information concerned.

In situations such as the following examples, the Company’s legitimate interests referred to in item 1. above may be prejudiced such that a delay in disclosure of Inside Information may be possible (provided that the other conditions for delay are simultaneously met):

• ongoing negotiations, where disclosure of the information would be likely to affect the outcome or normal course of the negotiations;

• the information concerns a serious threat to the Company’s financial viability, and immediate disclosure of the information would seriously prejudice the interests of existing and potential shareholders by jeopardising the conclusion of negotiations aimed at ensuring the Company’s financial recovery;

• the matter concerns a decision or a contract of the Company’s management body that requires the approval of another body of the Company to become effective, where disclosure of the information before such approval, together with a simultaneous announcement that this approval is still pending, would jeopardise the correct assessment of the information by the public;

• the information relates to progress in product development, patents or other inventions, and it is in the Company’s interest to protect that progress before the matter is disclosed;

• the information relates to the Company’s decision to sell or purchase a major holding in another company, and failing to delay disclosure would jeopardise the conclusion of the planned transaction; or

• the information relates to a previously disclosed transaction that still requires regulatory approval. In such situations, disclosure of any additional conditions imposed by the authority may be delayed if disclosure could jeopardise the completion of the transaction.

In situations such as the following examples, delaying disclosure of Inside Information would be likely to mislead the public (and delay of disclosure is therefore not possible in these situations):

• Inside information concerning a material change to forecasts, financial results or business objectives as previously publicly announced or communicated (such as, profit warnings or earning surprises).

• Inside information concerning a material change to the environmental or social impact of a project or a product as previously publicly announced or communicated (such as, environmental targets that are not met).

• Inside information concerning the financial viability of an issuer where materially different information regarding its financial conditions was previously publicly announced or communicated (such as, the need for a capital increase or an extraordinary bond issuance).

• Inside information concerning the fact that the results or the deadlines of a product or a project under development will not be met, where those results or deadlines were previously publicly announced or communicated.

• Inside information concerning a material change to the capital structure as previously publicly announced or communicated (such as, a significant modification in the issuance of financial instruments).

• Inside information concerning a material change in a business strategy that was previously publicly announced or communicated (such as, a decision to enter a new geographical market segment).

• Inside information concerning a material change to core elements of a contract or a deal that was previously publicly announced or communicated (such as, the termination of a commercial partnership, or, in the case of an acquisition, the choice of a different target company).

• Inside information concerning a material change to the corporate governance as previously publicly announced or communicated, including management structure and codes of conduct (such as, a decision to cancel a planned increase in the number of independent Board members).

Robit’s Board of Directors, or, in urgent cases, the CEO or the Chairman of the Board, makes the decision to delay disclosure of Inside Information. The decision to delay disclosure of Inside Information is documented, and a project-specific insider list is established for that purpose. The Company monitors whether the conditions for delaying disclosure continue to be met and discloses the delayed information as soon as possible after the conditions for delay are no longer met. Inside Information is not disclosed if the project to which the Inside Information relates lapses.

When the Company discloses delayed Inside Information, the Company shall notify without delay the Finnish Financial Supervisory Authority of the delay in disclosure. The reasons for the delay in disclosure are retained for at least 5 years and are provided to the Finnish Financial Supervisory Authority upon request. No decision to delay disclosure is made regarding interim steps of a protracted process, and no such decision to delay is submitted to the Finnish Financial Supervisory Authority in respect of them. However, the Company always ensures that inside information remains confidential, and a project-specific insider list is maintained for undisclosed inside Information.

3.4 Future outlook and its updating

In addition to what is stated in the various regulations and guidelines, Robit observes the following principles in its disclosure:

• If Robit’s financial performance for the financial year deviates unexpectedly and materially from an estimate that could reasonably be made on the basis of information previously disclosed by the Company, the Company discloses an updated profit guidance by way of a stock exchange release as soon as possible.

• The financial statements release and the interim reports also describe the Company’s most significant short term risks and uncertainties.

3.5 Customer contracts

Contracts entered into with customers are generally framework agreements intended to guide operations. As such, deliveries under the contracts are not necessarily guaranteed to materialise. As a rule, Robit does not disclose commercial contracts entered into with customers, owing to their confidential nature, unless the entry into the contract or another related matter constitutes Inside Information. If a matter relating to a contract is assessed to constitute Inside Information, the principles described above in Section 3.2 on protracted processes are taken into account during the negotiation phase.

3.6 Corporate acquisitions

Corporate acquisitions that are assessed to be likely to have a significant effect on the price of Robit’s Financial Instrument are disclosed in accordance with the ongoing disclosure obligation and the rules of Nasdaq Helsinki Ltd.

3.7 Information leaks, market rumours and crisis communications

• If Inside Information, the disclosure of which the Company has delayed or which relates to interim steps of a protracted process, leaks before it is disclosed, Robit discloses the information without delay.

• Robit does not comment on market rumours. However, if the Company’s management assesses that a market rumour is likely to have a significant effect on the price of Robit’s Financial Instrument, it may consider disclosing a release in order to correct false or misleading information or to provide the market with accurate information on an equal basis.

• Where a market rumour clearly relates to undisclosed Inside Information, that Inside Information is disclosed as soon as possible once the rumour is sufficiently precise to indicate that the confidentiality of that information can no longer be ensured.

• At the request of Nasdaq Helsinki Ltd, the Company discloses information in special situations or circumstances that give rise to significant uncertainty regarding the equal trading in, or the reliable price formation of, its Financial Instrument on the Exchange.

• In crisis situations, the local management of Robit’s business units initiates crisis management measures, including communication measures. If the Company’s management assesses the situation to be so serious that it is likely to have a significant effect on the value of Robit’s Financial Instrument, responsibility for communications is transferred to Robit’s group communications function, and a stock exchange release on the matter is published as soon as possible.

3.8 Investor relations and the silent period

The Company holds investor meetings regularly in connection with the disclosure of financial reviews. Investors are also met at investor events organised by the Company and by other parties.

Robit’s so-called silent period begins 30 days before the disclosure of an interim report or the financial statements release and ends upon their disclosure. No investor meetings are held during the silent period, and the Group’s results and performance are not commented on.

If an event occurring during the silent period requires immediate disclosure, the Company discloses the information without delay in accordance with the provisions on the disclosure obligation and may comment on that event.

Stock exchange releases are published through Nasdaq Helsinki Ltd in Finnish and in English and are delivered simultaneously to the key media. The Company also publishes releases on its website as soon as possible.

Guidance on the interpretation and application of this Disclosure Policy is given by the CEO or a person designated by them.

The Company’s Board of Directors decides on amendments to, and the approval of, the Disclosure Policy.