Outokumpu's Insider Rules are based on and comply with the Guidelines for Insiders by NASDAQ OMX Helsinki.
The Company’s permanent insiders with a duty to declare consist of the members of the Board of Directors,
the Auditor in Charge, the CEO and his deputy, as well as the other members of the Group Executive Committee.
Outokumpu maintains a public register on the permanent insiders with the duty to declare. Employees
of the Group who receive inside information on a regular basis due to their positions or tasks are registered in
a non-public register of permanent company specific insiders. Permanent insiders must not purchase or
sell securities issued by the Company in the 14 days prior to publication of interim reports or annual
accounts (the so called closed window).

Separate non-public project-specific insider registers are maintained for insider projects. Persons defined as
project-specific insiders are those who in the course of their duties in connection with a project receive information
concerning the Group which, when realized, is likely to have a significant effect on the value of the company’s
publicly traded securities.

Outokumpu's General Counsel is responsible for coordinating and supervising insider issues.
Up-to-date information on holdings by Outokumpu's permanent insiders with a duty to
declare can be found here. 

The register of insider holdings is available for public inspection at the Outokumpu head office.