Insiders

Detection Technology Plc (“DT”) follows the insider guidelines approved by the Board of Directors and based on the Market Abuse Regulation (“MAR”), the insider guidelines of Nasdaq Helsinki Ltd, and other appropriate rules and guidelines.

DT has identified as managers (“managers”) required to report transactions in DT financial instruments for the purposes of MAR, the members of the Board of Directors, the President and CEO, and the members of the Management Group (including persons closely associated with them for the purposes of MAR). Managers are subject to a restriction on trading (closed window) on DT financial instruments for a period of 30 days prior to the day after publication day of the company’s financial statements or interim reports.

In addition, the company has designated some DT employees as persons working in the company’s information core who, by virtue of their duties, have access to the company’s information core (“persons working in the information core”). These persons typically include persons who prepare an interim or annual financial reports, persons responsible for the company’s finances, financial reporting or communication, or other persons in the company’s management positions. These persons are also subject to a 30-day restriction on trading (closed window) ending on the day after publication of financial results.

Furthermore, the Company maintains project-specific insider registers. Persons involved in the planning and preparation of projects or events concerning inside information are considered as project-specific insiders. A project-specific insider must not trade or conduct other transactions in the company’s financial instruments during the project. The prohibition also applies to their dependent children and to entities under their direct or indirect control.

The person in charge of insider matters for the company is DT’s CFO.

The company voluntarily maintains on its website a list of the financial instruments owned by its managers or their controlled corporations. The list of managers’ holdings is updated automatically every month, and is based on the information provided by the Euroclear Finland Ltd.

Holdings of managers