Insiders and insider register

The Company has a policy which covers dealings in securities and applies to public as well as company- and project-specific insiders.  A comprehensive register of public insiders consisting of the Directors, the members of the Executive Committee, the auditor of the Company and any other person whose holding of shares shall be public according to the Finnish Securities Markets Act, is maintained by the Company and available on the Company website and headquarters.

Talvivaara's register of company-specific insiders includes individuals who are defined by the Company as such and who regularly possess insider information due to their position within the Company. The Company also maintains a project-specific insider register when necessary. Project-specific insiders are prohibited from trading in the Company's securities until the termination of the relevant project. All insiders are notified of close periods.

Permanent insiders may not trade in securities issued by the Company during closed periods defined pursuant to section 1 of the Model Code annexed to the UK Listing Rules (the "UK Model Code"). The Company also follows the Insider Guidelines issued by NASDAQ OMX Helsinki (the "Finnish Insider Guidelines"). As the closed periods under the UK Model Code are longer than the minimum closed windows under the Finnish Insider Guidelines, the Company has decided to define its closed periods in accordance with UK Model Code as follows:

• the period of 60 days immediately preceding preliminary announcement of Company's annual results or, if shorter, the period from the end of the relevant financial period up to and including the time of announcement; and
• the period of 30 days immediately preceding the announcement of the quarterly results or, if shorter, the period from the end of the relevant financial period up to and including the time of the announcement.