Insider administration

Fortum complies with the EU regulation No. 596/2014 on market abuse (MAR) and EU regulation No. 1227/2011 on wholesale Energy Market Integrity and Transparency (REMIT) and related regulation. Fortum complies also with the Guidelines for Insiders issued by
Nasdaq Helsinki.
 

Persons discharging managerial responsibilities

Persons discharging managerial responsibilities and the persons associated with them are under a duty to disclose their transactions
with Fortum’s financial instruments. Fortum has defined persons discharging managerial responsibilities to be the members of the
Board of Directors and Fortum Executive Management.
 

Duty to disclose and Closed Window

Fortum’s Board of Directors and Executive Management members as well as persons related to them are under a disclosure duty towards
Fortum and the Finnish Financial Supervision Authority regarding their transactions with Fortum’s financial instruments. Fortum makes
the said transactions public with a stock exchange release.
 
Fortum’s Board of Directors and Executive Management members as well as other Fortum personnel defined to have access to sensitive
financial information of Fortum may not trade in Fortum’s financial instruments within 30 days prior to the publication of interim reports
and financial statements (Closed Window).
 

Internal supervision of insider affairs

Fortum’s own internal insider rules are regularly updated and made available to all employees of Fortum. Fortum arranges training
on insider rules. The coordination and control of insider affairs are included in the responsibilities of Fortum’s General Counsel.
Fortum regularly monitors the trading of its insiders.

2/17/2017