Outokumpu's Insider Rules are based on and comply with the Guidelines for Insiders by the
OMX Nordic Exchange 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 security.

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.