Lindex Group plc’s disclosure policy

This disclosure policy, approved by Lindex Group’s Board of Directors, describes the main principles in accordance with which Lindex Group, as a listed company, communicates with the capital markets and other stakeholders.

In its disclosure policy, Lindex Group complies with Finnish law, the Financial Supervisory Authority’s standards and instructions, and the rules of Nasdaq Helsinki.

The purpose of Lindex Group’s disclosure policy is to ensure that in order for market actors to be able to establish the correct value of the Lindex Group share, sufficient and accurate information on the Lindex Group is available to them at the same time. The disclosure policy also ensures that published information is provided promptly and impartially.

The company’s CEO is responsible for the implementation of the disclosure policy. The other members of the management participate where their area of responsibility is concerned. Lindex Group’s Communications & CSR function executes the disclosure policy in practice.

Modes of operation

Lindex Group publishes information on its financial situation in accordance with a timetable that is notified in advance. The publication dates for the upcoming financial period are published before the end of the previous financial period. Information on the financial position, future outlook, profit performance and other similar matters is provided primarily in interim reports and financial statement bulletins. Profit guidance regarding future outlook is expressed in words. If any information concerning these matters that may have a material impact on the value of Stockmann’s share is given between the publishing of these quarterly reviews, this information is always published in a stock exchange release.

Financial data are published on the parent company, the Lindex Group as a whole and its segments. The Group’s operating segments are Stockmann and Lindex. Secondary segments are the Group’s market areas.

Lindex Group’s stock exchange releases are approved by the company’s CEO or CFO.

Lindex Group’s stock exchange releases are always published in Finnish, Swedish and English. Investor information published on the company’s website is published in Finnish, Swedish and English.

Rumours, market assessments and leaks

Lindex Group does not comment on rumours circulating on the markets, share price performance, the actions of competitors, or analysts’ forecasts, unless this is necessary in order to rectify information that is obviously incorrect. If, however, inside information, or other information that has a material impact on Lindex Group’s share price is prematurely leaked to the public, the company will publish a stock exchange release on the matter.

Contacts with investors, analysts and the media

On its website Lindex Group publishes a list of the analysts that, according to the information received by the company, monitor Lindex Group’s performance on their own initiative. Lindex Group does not publish or distribute assessments regarding the company made by outsiders, such as reviews or consensus reports.

Lindex Group aims to promptly respond to questions from investors, analysts and the media.

Lindex Group arranges investor and analyst conferences in connection with the publication of its interim reports and financial statement bulletins.

Members of Lindex Group’s management meet representatives of the capital markets and the media. The aim of these meetings is to provide background information on Stockmann and its operating environment. The discussions are based on information either published previously by Lindex Group or that is widely available on the market, and no new information that might affect the value of the company’s share is disclosed.

Insiders and managers’ transactions

Lindex Group complies with the Guidelines for Insiders prepared by the Nasdaq Helsinki (the link will open on Nasdaq’s web pages).

Lindex Group publishes notifications of all transactions conducted by persons discharging managerial responsibilities in accordance with the regulations of the EU’s Market Abuse Regulation (MAR). Persons discharging managerial responsibilities refer to members of the Board of Directors, the CEO, and the members of the Group Management Team. Notifications of transactions are published within three business days from the date of the transaction.

Lindex Group’s Board of Directors has decided that the restriction on trading in the company’s shares by persons discharging managerial duties is 30 days before the publication of an interim report or the financial statements.

Silent period

Lindex Group observes a 30-day silent period before the publication of the interim report and the financial statement bulletin. During this time Lindex Group does not comment on the company’s financial position, earnings performance or its future outlook.

Communication channels

Lindex Group uses stock exchange and press releases, financial reports, its website, and meetings and events as the main channels of communication.

Lindex Group plc’s stock exchange releases are published without undue delay on the company’s website, where they are available for a minimum of five years from the date of disclosure. The releases are also stored in a national release archive maintained by Nasdaq Helsinki.

Crisis communication

A crisis is an unexpected, extraordinary event that seriously jeopardises Lindex Group’s operations, the fulfilment of its customer promise, or its shareholder value or reputation. Crisis communication is a part of the company’s risk management, and its objective is to ensure that the necessary communication measures can be implemented quickly and efficiently in such crisis situations.

Approved by Stockmann’s Board of Directors on 11 June 2019. Effective from 1 July 2019.

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