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Insider Management

Insider regulations

The company complies with the Market Abuse Regulation (596/2014, "MAR") and the Securities Market Act and related regulations and guidelines issued by the European Securities Markets Authority, the Finnish Financial Supervisory Authority and Nasdaq Helsinki Ltd.

Moreover, the Board of L&T’s has also verified insider guidelines to supplement the Guidelines for Insiders issued by Nasdaq Helsinki Ltd. Certain key aspects of the insider guidelines are described below. The insider guidelines clearly specify certain practices and decision-making procedures foe ensuring that the company’s insider management has been arranged in a consistent and reliable way. The General Counsel is responsible for insider issues in the company.

Management Transactions

Persons holding management positions in the company, such as members of Board of Directors and President CEO, and their close associates, are required to notify L&T and the Finnish Financial Supervisory Authority of all transactions involving financial instruments issued by L&T or related to L&T.

Transactions by managers and the persons closely associated with them are published as stock exchange releases via the company website.

Insider Projects

As a result of MAR, L&T has not had a public insider list since 3 July 2016. L&T also no longer maintains a permanent company-specific insider register. Instead, the company’s employees and service providers with access to certain insider information are recorded in project-specific lists of insiders. Service providers may keep a list of insiders concerning their own employees if so decided by the company in an individual case.

Trading Restrictions and Closed Period

If a person holds inside information, trading in the company’s securities is always prohibited. In addition, certain trading restrictions apply to certain managers and employees of the company also when said parties hold no inside information.

L&T has specified the Board of Directors and the CEO as executives as referred to in the Market Abuse Regulation.

Said persons may not trade in L&T’s financial instruments on their own account or for the account of a third party for a closed period of 30 days preceding the publication of the company’s interim reports, half-year report and financial statements release, including the date of publication.

The closed period preceding result announcements and the restriction of trading during the closed period also apply to the persons who participate in the preparation of interim reports and the financial statements release, or who otherwise have regular access to L&T’s undisclosed financial information.

Reporting Breaches

L&T has a confidential channel for reporting suspected violations of securities markets regulations. The channel is maintained by an external company independent of L&T. Within L&T legal affairs are responsible for the reporting channel, conducting investigations, and for taking further action.