Corporate Governance Statement,
Reporting Period Jan. 1–Dec. 31, 2016

Insider Guidelines

The Company adheres to the Insider Guidelines for Listed Companies prepared by Nasdaq Helsinki Ltd (previously NASDAQ OMX Helsinki Ltd, OMX Nordic Exchange Helsinki Ltd and Helsinki Stock Exchange), the Central Chamber of Commerce and the Confederation of Finnish Industries. The Company has complemented the Guidelines by its internal insider guidelines. The insider and trading guidelines approved by the Company include regulations on insiders, publication and postponement of publication of inside information, prohibited use of inside information, insider registers, duty of notification of managers´ and their closely associated persons´ transactions, and personnel´s own trading with specific financial instruments. The purpose of the guideline is to explain the content of the guideline published by Nasdaq Helsinki Ltd and other regulations and restrictions relating to the matter, and to unify and coordinate the processing of insider and trading matters within Bittium.

The managers of the Company must comply with the EU Market Abuse Regulation´s prohibition on dealing in the Company´s financial instruments (closed period). In accordance with the Company´s Board of Directors´ decision, the Company has in addition determined certain time periods during which persons taking part in the preparations of the Company´s financial reporting, and other persons who have access to information pertaining to the Company´s financial status, are prohibited to trade the Company´s financial instruments. The purpose of the trade restrictions is to control trading of the Company´s financial instruments, and thereby increase trust to the Company and the operation of the securities market. Trading with the Company´s financial instruments is completely prohibited for the aforementioned persons for a period of 30 days before the publication of earnings information of the Company. The most common publications are the release of interim reports and release of the Company´s financial statements. The restriction is applicable also to any possible preliminary information regarding the financial statements and interim report.

Persons included in a project-specific insider register are prohibited from all trading and business transactions until the project has expired or has been publicly announced. If the project falls upon another listed company or may affect the price of the financial instruments of another listed company, the project-specific insiders have no right to trade with such company´s financial instruments.

The Company voluntarily maintains on its website a list of the financial instruments owned by the Company´s managers or by the institutions operating under the authority of the managers. The list is updated on the last day of each month.