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Disclosure Policy

General principles

The aim of Efecte Plc’s communication is to ensure that all market participants have simultaneous and timely access to sufficient, reliable, essential, and consistent information on the company and matters influencing the value of the company’s financial instruments.

The company’s communication is based on the following main principles:

• Communication is equal, consistent, regular, and transparent

• The published information is accurate, reliable, and relevant

• Relevant information is published in a timely manner

• The published information is readily available to investors, market representatives, and company’s stakeholders

In its communication and disclosure, Efecte complies with the EU Market Abuse Regulation (MAR), the European Securities and Markets Authority as well as the rules and regulations set for companies listed on the Nasdaq First North Finland. The company’s certified advisor is Evli Bank Plc.

Disclosure principles

The highest decision-making power regarding external communication is vested in the Board of Directors. The operating responsibility of the implementation of the disclosure policy lies with the company’s CEO and CFO. The company’s certified advisor revises and approves all company announcements before publication.

Disclosure of financial information and financial targets

Efecte discloses a half-year financial report and financial statements bulletin according to a previously announced schedule. In addition, the company discloses two business reviews during the year (first and third quarter), which are more compact than the half-year financial report. Efecte reports on the financial targets and outlooks in the financial statements bulletin or half-year financial report. Efecte discloses its financial targets only for the whole financial year. The company does not comment on expectations made by capital market representatives and is not responsible for their estimates.

Silent period

Efecte observes a 30-day silent period preceding the publication of its half-year results or publishing of other financial reviews.

During the silent period, Efecte refrains from commenting the company’s financial results, market, or financial outlook. During the silent period, the company management refrains from meeting representatives of capital markets or financial media, and does not comment on the company’s financial situation or general business issues. The company may, however, respond to enquiries related to communication about business operations at the current time.

Disclosure and delay of inside information

In accordance with the Market Abuse Regulation (MAR), Efecte discloses inside information, which directly concerns the company, as soon as possible by a company announcement.

The Company shall assess on a case-by-case basis whether the aforementioned conditions for delaying disclosure are met. If all the conditions listed above are not met, the Company must publicly disclose the inside information as soon as possible by means of a company announcement. When the company assesses whether information is inside information or not, the company shall take into consideration the anticipated impact of the information in light of the totality of the company’s activity and any other market variables likely to affect the price of the company’s financial instruments in the given circumstances.

Efecte may, on its own responsibility, delay disclosing inside information to public if the following conditions are met:

• immediate disclosure is likely to prejudice the legitimate interests of the company;

• delay of disclosure is not likely to mislead the public; and

• the company is able to ensure the confidentiality of the inside information.

The decision to delay disclosing inside information is made by the CEO or a person appointed by him/her based on a written statement on the fulfilment of the conditions on delaying inside information.

Press releases

Press releases are used to announce matters which do not meet the criteria for stock exchange releases but are deemed to be of value as news items. Press releases can be published globally or regionally, and they are also typically published on Efecte's website.