This Disclosure Policy describes the key operating principles that Easor, as a listed company, observes in its investor communications and financial reporting, and when communicating with its shareholders and other capital market participants, the media, and other stakeholders. The Disclosure Policy is reviewed and updated as necessary.

Easor's shares are listed on Nasdaq Helsinki's official list. In its communications, Easor complies with EU and Finnish legislation, the rules and guidelines of Nasdaq Helsinki, the regulations and guidelines of the European Securities and Markets Authority ("ESMA") and the Finnish Financial Supervisory Authority (“FIN-FSA”), as well as the Company's internal policies and guidelines.

The key principles of the company's communication are timeliness, consistency, impartiality, and transparency.

The purpose of the Company's investor relations function is to support the correct valuation of Easor's financial instruments by providing the financial markets with consistent, accurate, relevant, and reliable information about the Company. This ensures that capital market participants have a transparent and clear picture of the Company, its operations, objectives, operating environment, strategy, and financial position. The aim is to ensure that all market participants receive information communicated by the Company simultaneously.

The Company publishes any direct insider information it has concerning the Company as soon as possible in a stock exchange release, unless there are grounds for delaying the disclosure of insider information in accordance with the Market Abuse Regulation ((EU) No 596/2014, "MAR"). In accordance with MAR, Easor may, on its own responsibility, delay the disclosure of inside information, provided that all of the following conditions are met:

(a) immediate disclosure would likely jeopardize the legitimate interests of the Company;
(b) delaying disclosure is unlikely to mislead the public ; and
(c) The Company is able to guarantee the confidentiality of this information.

The Company must assess on a case-by-case basis whether the aforementioned conditions for delaying disclosure are met. The decision to delay the disclosure of inside information is made by the Company's CEO or a person appointed by them, based on an assessment of whether the conditions for delaying the disclosure of inside information are met. If all the above conditions are not met, the Company must disclose the inside information as soon as possible by means of a stock exchange release.

When the disclosure of information is delayed, Easor must document the conditions for delaying the disclosure and publish the information as soon as possible when the conditions for the delay are no longer met. The assessment and the decision to delay disclosure must be made in writing, the decision must be dated (including the time), and the assessment and decision must be retained for at least five years from the date they were made. The Company's CEO is responsible for the retention. The FIN-FSA must be notified of the decision to delay the disclosure of inside information immediately after the information has been disclosed. When the Company decides to delay disclosure, an insider list is drawn up for the inside information in question.

4.1 Regular Communications

Easor regularly publishes information on the Company's results, balance sheet and financial position, outlook, and other related matters and their development primarily in its Financial Statements Release, Half-Year Report (H1), and Business Reviews (Q1 and Q3). The Company publishes an annual report every year. In addition, Easor publishes its Financial Statements, the Board of Directors' Report and the Auditor's Report, as well as a statement on the Company's Corporate Governance Policy and Remuneration Report.

Easor publishes its financial reports according to a pre-announced schedule. The publication dates for the upcoming financial year are aimed to be announced on the Company's website before the end of the previous financial year. The company's financial year is the calendar year.

4.2 Outlook

Easor will publish an estimate of the Company's future outlook and a potential earnings guidance in its financial statements release, should the Company's Board of Directors so decide. Easor presents an assessment of the key factors and risks influencing the Company's future development in its Financial Statements Release, Half-Year Report, and Business Reviews. In addition, they are published on the Company's website and in the Annual Report.

4.3 Profit Warnings

4.3.1 Issuing a Profit Warning

Easor continuously monitors the Company's financial performance, position, and future outlook. A profit warning will be published when the Company reasonably expects that its future prospects are weaker or better than previously published estimates, and the deviation is likely to have a significant effect on the price of Easor's financial instruments.

In accordance with MAR, information that would be likely to have a significant effect on the price of financial instruments means information that a reasonable investor would be likely to use as part of their investment decision.

The following general guidelines are used when assessing the need to issue a profit warning. The guidelines mentioned below are indicative, and the Company always assesses the necessity of an earnings warning on a case-by-case basis, considering previously disclosed information and prevailing market conditions. The publication of a profit warning cannot be delayed.

If the Company does not provide numerical guidance on its future prospects, it must review and confirm the principles for assessing the need to issue a profit warning. These principles may include percentages used to assess the need for a profit warning, taking into account that prevailing market conditions and expectations may necessitate a profit warning even if the percentage thresholds are not exceeded.

If the Company has published guidance that includes, for example, a revenue or operating profit range, the main principle in assessing the need to issue a profit warning is whether the estimated financial indicator falls within the given range or not.

4.3.2 Profit Warning Issuance Process

The Board of Directors decides on issuing a profit warning, primarily based on the CEO's proposal.

The CEO shall immediately notify the Chairman of the Board if the CEO, CFO, another Company official, or a Board member identifies a need to consider issuing a profit warning. Primarily, the Company's CEO and CFO, together with the Chairperson of the Board, assess and decide on the need to issue a profit warning.

The Chairperson of the Board may, at their discretion, decide to issue a profit warning if, in exceptional circumstances, it is not possible to convene a Board meeting quickly enough. The Chairperson of the Board shall keep the members of the Board informed of his decision-making.

5.1 Communication Channels

Easor's website (investors.easor.com/fi/ in Finnish and investors.easor.com/en/ in English) is the primary communication channel for disseminating up-to-date information to all stakeholders. Easor aims to provide reliable and comprehensive information on its website to enable investors to form an accurate picture of the Company. The Company also makes materials used in investor and analyst meetings available on its website.

Easor's stock exchange releases are published through a professional news distribution service provider (which includes distribution to Nasdaq Helsinki and key media, for example), and on the Company's website, where they are made available upon disclosure or other publication. Press releases are distributed to key media outlets and published on the Company's website. Easor's releases can be subscribed to on the Company's website. Stock exchange releases are archived for 5 years and financial reports and other regular reports for 10 years.

Easor's official reporting language is Finnish. Stock exchange releases and financial reports subject to disclosure requirements are published in both Finnish and English. If necessary, releases may also be published in other languages.

5.2 Easor’s Release Types

5.2.1 Stock Exchange Releases

Stock exchange releases are used to disclose information on facts, matters and circumstances that Easor believes are likely to have a significant effect on the price of Easor's shares and other financial instruments. A stock exchange release is also used to disclose regulated information that requires such a release (such as managers' transactions, notices of General Meetings and their resolutions, and significant changes in the Company's management), even if such releases do not typically contain price-sensitive information.

For example, the following events, if material to Easor, are generally considered price-sensitive for Easor:

• Changes to Easor's previously disclosed outlook and/or financial performance and position;
• Significant investments;
• Strategy and significant changes to it;
• Significant mergers, acquisitions, divestments, demergers and other corporate reorganisations concerning Easor, as well as other significant contractual arrangements;
• Re-direction of Easor's business, restructuring programmes or programmes related to improving results;
• Significant organisational changes;
• Significant related-party transactions for the Company and its shareholders;
• Significant litigation and significant administrative proceedings, and decisions or judgements rendered therein; and
• Issuances of Easor shares or other financial instruments, public tender offers, stock splits, or changes in the number of shares.

Disclosure obligation generally guides the assessment and decision-making related to the publication of stock exchange releases. This assessment is carried out simultaneously with the process of evaluating the conditions for delaying the disclosure of inside information.

In addition to the above, the Nasdaq Helsinki rules define other matters to be disclosed as stock exchange releases. When assessing the need to publish a stock exchange release, attention is paid to whether similar matters have been previously disclosed via a stock exchange release or whether similar information has previously had a significant impact on the price of a financial instrument.

Easor’s CEO and the Company’s legal advisor review stock exchange releases, and the Company’s Board of Directors approves them before their publication.

5.2.2 Press Releases

The Company also publishes press releases concerning its business events that do not meet the criteria for stock exchange releases but are estimated to have news value or otherwise be of general interest to the media and the company's stakeholders. The Company may also publish press releases on local news.

Easor also publishes press releases including invitations to results publications and potential capital markets days.

5.2.3 News

In addition to stock exchange and press releases, Easor publishes news on its website that is not automatically sent to the media or other subscribers of the Company's releases. These news items can be followed on the Company's website. In some situations, the Company may also publish these less material matters through Nasdaq Helsinki to key media outlets.

5.3 Silent Period and Closed Window

Easor observes a 30-day silent period before the publication of Financial Statements, Half-Year Reports, and Business Reviews. During this period, the company's representatives do not meet with capital market representatives, nor do they give interviews or comment on the company's financial status or future prospects.

The dates for earnings releases and quiet periods are presented in the investor calendar on the Company's website.
If an event requires immediate disclosure during the quiet period, Easor will disclose the information without delay in accordance with disclosure obligations and will decide on interviews on a case-by-case basis, limiting its communication to the relevant event only.

Easor observes a closed window prior to its earnings releases. During the closed window, Easor's management or persons involved in the preparation of financial reporting, or persons under their control or guardianship, may not carry out, directly or indirectly, on their own account or on behalf of a third party, transactions related to Easor's shares or debt instruments or related derivatives or other financial instruments. The closed window begins 30 days before the publication of the Company's Business Review or Financial Statements and ends on the day following the publication.

The Company's leadership subject to the closed window are:

1. The company's Board of Directors and their potential deputies;
2. The company's CEO and their potential deputy;
3. Members of the Company's Management Team.

Individuals subject to the closed window are responsible for complying with the trading restriction, even when the management of their financial instruments has been entrusted to another person, such as a portfolio manager.

6.1 Communication with Investors and Analysts

Easor's communication aims for effective engagement with various capital market stakeholders. Easor actively seeks to meet with capital market and media representatives and, except during silent periods, promptly responds to inquiries from investors, analysts, and the media. Easor's management meets with investors and equity analysts at roadshows and meetings to present the Company, its business, strategy, and financial results.

Information is provided to investors, analysts, and the media at meetings within the framework of previously disclosed information and precisely in accordance with such information. No new undisclosed information or supplementary information that, together with previously disclosed information, could constitute inside information, will be provided at these meetings. Investor presentations are available on Easor's website.

Easor continuously monitors market expectations. Upon request, the Company may review models prepared by analysts, but only for factual accuracy and publicly available information. Easor does not comment on or take responsibility for the estimates or expectations of capital market representatives. The Company does not comment on its valuation or share price performance, grant privileges to any specific analyst, or distribute analyst reports to the investment community.

6.2 Responsible Persons and Representatives

The company's CEO and Board of Directors comment on the company's financial position and published outlook. Only Easor's CEO, or the company's Board of Directors if the CEO is unavailable, has the right to issue public statements regarding company information. Other individuals may only issue statements as authorized by the CEO. Other Easor representatives may also attend investor meetings at the CEO's request.

The company's CEO makes disclosure decisions or decisions to delay the disclosure of inside information and informs the Board of Directors of significant orders or agreements received by the company, situations significantly affecting financial performance (see section 4.3 above), significant lawsuits filed by or against the company, and other legal proceedings or regulatory actions that are estimated to constitute inside information concerning the company.

The company's Board of Directors decides on the disclosure of other matters subject to continuous and regular disclosure obligations. The company's legal counsel, together with the CEO, is responsible for compliance with regulations related to investor relations and for disclosure. Easor's investor relations function prepares and coordinates all events and presentations for shareholders, investors, and analysts, and is responsible for preparing financial reports and stock exchange releases. The investor relations function handles inquiries from shareholders, investors, and analysts and comments on the company's operations and development as needed.

Easor's CEO is responsible for overseeing and interpreting this Disclosure Policy and for investor relations. Operational responsibility for communications rests jointly with the CEO and the Communications Director. If the CEO is unavailable, the Board of Directors assumes responsibility, and if the Communications Director is unavailable, the Administrative Director assumes responsibility.

6.3 Crises

In the event of a crisis or a situation that may develop into one, the Company's CEO, or the Board of Directors if the CEO is unavailable, will assemble a crisis management team to manage the situation and related communications. Easor aims to ensure that the right people are available to the media and other stakeholders, even in a crisis.

Depending on the situation, communications may be centralized under a designated person. Crisis communications emphasize ensuring the accuracy and quality of information to be disclosed, as well as honesty and speed.

6.4 Rumours, Market Estimates and Data Breaches

As a general rule, Easor does not comment on potential market rumours or speculation, share price performance, competitor or customer actions, or analyst estimates, unless it is necessary to correct materially incorrect information when such incorrect information is likely to have a significant impact on the price of the Company's financial instruments.

If the rumour concerns inside information that has been subject to delayed disclosure, and if the information is so precise that its confidentiality can no longer be guaranteed, the Company will disclose the matter via a stock exchange release as soon as possible, in accordance with the rules and procedures concerning market abuse and the disclosure of inside information.

Easor does not correct analyst estimates or comment on the Company's valuation or share price performance. Easor is not responsible for and does not comment on any estimates made by capital market representatives. Upon request, the Company may review an analysis or report prepared by an analyst for factual accuracy but will not comment on the conclusions drawn.

In the event of an insider information leak (or potential leak), the CEO or the Company's legal counsel must be contacted immediately. The CEO is responsible for disclosing information regarding data breaches. The CEO may authorize another executive to issue clarifying statements on the matter. If rumours have had or could have a significant impact on the share price, the Company should consider discussing the situation with Nasdaq Helsinki's market surveillance.

6.5 General Meetings

The CFO is responsible for organizing general meetings, and the Chairperson of the Board is responsible for their content. The Company's communications department is responsible for preparing and distributing releases related to the meeting.

In its insider guidelines and insider administration, Easor complies with the requirements of MAR and the regulations and provisions issued thereunder, the regulations and guidelines of the FIN-FSA, and the rules and guidelines of Nasdaq Helsinki. The insider guideline addresses the disclosure of inside information and forms an essential part of this Disclosure Policy. The disclosure rules also bind Easor's personnel. If inside information is disclosed to personnel, these individuals are informed that the Company's insider regulations also apply to them. They are recorded as insiders in the insider list maintained by the Company. In connection with the Company's listing process, Easor's personnel have been trained on what is involved in being an insider in a listed company and how a listed company must act within the framework of its disclosure obligations.

Within the framework of applicable laws and regulations, the Company has the right to deviate from this Disclosure Policy in individual cases due to compelling reasons, in which case the Company's CEO decides on the deviation. The CEO is also responsible for overseeing and interpreting the Disclosure Policy and, if necessary, provides further guidance on its practical implementation.
The Company's Board of Directors decides on any changes to the Disclosure Policy. The CEO may make minor or technical amendments to this policy.