Summary Communication and Insider Policies

April 2017

Why a Communication Policy?

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�To meet Nasdaq Stockholm´s listing requirements regarding disclosure of financial and other price sensitive information.

�Supply the Capital market with Accurate, Relevant and Reliable information without delay and at the same time.

�But also, a tool for managers regarding communication objectives and responsibilities including contact with media and the financial community.

�Strengthen the confidence in Actic Group, its offer and brand, management and employees.

Scope

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�The requirements of the policy apply to Board of Directors, ALL employees, consultants etc. in all markets at all time.

�Both WRITTEN information and VERBAL statement.

� Inconsistent with the policy must be promptly corrected (and may subject to disciplinary action from authorities).

�Audience

�Authorities

�Financial community and journalists

�Customers and competitors

�Employees and partners

Principles for our information

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�Long term perspective and in accordance with Groups’ brand, objectives, strategy and values.

�Open, honest, prompt, controlled and professional.

� In accordance with regulations from Nasdaq and the Corporate Governance.

Disclosure

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�Regular disclosure obligations

�Continuous disclosure obligation

�Other regulated disclosure obligations

� In accordance with the new Market Abuse Regulation “MAR” effective from 3 July

� Immediate disclosure

� If delay – not likely to mislead the public

� Ensure the confidentiality of the information

� CFO (and Head of IR) responsible for decisions on whether or not to delay – if delayed written explanation to authorities.

Regular disclosure obligations

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�The regular disclosure requirements are based on financial reporting and such will serve as the primary source of information for estimating the company’s financial status, development and valuation.

Continuous disclosure obligations

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�The continuous disclosure obligations refer to actual decisions, transactions, operations and day-to-day business underlying the financial information and serves as a supplement to the regular financial information especially between the regular reporting dates.

Continuous disclosure obligations, examples…

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Decisions related to:

• Personnel changes in Group management

• Changes in the Board of Directors

• Change of auditor

• Changes in corporate strategy and vision

• Change of business model

• Major organizational changes, restructurings/lay offs

• Material investment

• Issuance of securities

• Assets distribution

• Repurchase of shares

• Other material changes in capital structure

• Market making agreements

Continuous disclosure obligations, examples…

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Events/circumstances related to the operations of the Group, such as:

• Acquisitions, disposals and mergers of material assets (“5 % rule”: sales/assets/ equity)

• Entering into or termination of significant agreement

• Material investment

• Business interruption

• Loss of assets

• Commencement, settlement or judgment on material legal disputes or proceedings

• Material administrative proceedings, including tax

• Major changes in commercial/ product and operational strategies

• Decisions taken by the authorities (both to initiate and to complete a process)

• Financial difficulties

• Information regarding subsidiaries and affiliated companies

Events not be disclosed or commented

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�Market rumours

�The company is not obliged to monitor market rumours or respond to rumours which are without substance or other inaccurate etc.

�Matters in preparation

�Other matters of similar nature

Silent Period

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�30 days before the issue of each of the quarterly reports.

�Ends the moment when each of the respective quarterly reports is presented.

�During the silent period, Actic Group does not comment on issues related to the company’s financial situation or general outlook.

Basic rules of communication

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�General questions are forwarded to the Market Director.

�Questions regarding financial issues are directed to the CFO or Investor Relations function.

�Only appointed spokespersons have the right to speak or make official statements on behalf of Actic Group and its subsidiaries.

�Actic Group’s communication languages to the capital markets are Swedish and English. Local information (marketing) in local language.

�All corporate level financial information aimed at being published shall be coordinated by the CFO.

IR-module at www.acticgroup.se

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Summary Insider Policy

April 2017

What is inside information?

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“Inside information refers to

information of a precise nature which

has not been made public and which,

if it were made public, would be likely

to have a significant effect on the

price of the company’s financial

instruments”.

An insider

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� Insider – a person with access to inside information in a listed company.

�An insider is prohibited from buying or selling financial instruments.

� Insiders are also prohibited from spread inside information or encouraging others to engage in trading activities based on said information.

� Insiders are not allowed to disclosure inside information to persons who do not require the information in order to perform their job.

Note all insiders at Actic will be noted in written via a mail from CFO – the mail need to be confirmed….

Why an Insider Policy

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�The purpose of the Insider Policy is to ensure that Actic and all individuals concerned follow all applicable laws, regulations and internal rules regarding the dissemination of information in listed companies and trading in the company’s securities.

�CFO is in charge of insider issues including:

– Regularly updating permanent and event-based insider lists

– Notify insider their obligations and documenting their receipt

– Granting permission for insiders to trade in Actic shares etc…

Individuals covered by the policy

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� All individuals covered by Actic’s Insider Policy will individually be notified by the CFO and receive a copy of the Insider Policy.

� Permanent insider list includes persons who, through their position in the company, is deemed to have access to all undisclosed and price-sensitive information concerning the company, and responsible for informing the persons closely related to them of their obligations.

� Persons who only have access to undisclosed and price-sensitive information for a limited period of time are to be registered in the event-based insider list.

� INSIDERS MUST OBTAIN PERMISSION FROM CFO BEFORE TRADING.

� Permanent insider must report transactions to the Swedish Financial Supervisory Authorthy’s website within three days.

Extended obligations and trading ban

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�According to MAR (EU:s Market Abuse Regulation), insiders are only obligated to report their trading activities when a total transaction amount of EUR 5,000, calculated without netting, has been reached within a calendar year. In this respect, however, Actic has chosen to go further than the law and requires that all insiders report all of their trading activities to the CFO.

� Insiders are subject to a ban on trading in securities in Actic during the 30 days prior to the publication of Actic’sregularly scheduled financial reports. The trading ban also applies on the entire day of publication.

Other employees trading in Actic Shares

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� If you are in possession of information that could be presumed to impact the share price and you are not certain has been disclosed through a press release, you are prohibited by law from using this information.

�Be restrictive when it comes to buying and selling Acticshares in the 30 days prior to the publication of each interim report.

�Consider your reasons. Do you feel driven by a sense of hope or concern? If so, are your feelings based on information or observations that you are not certain have been disclosed to the public through a press release.

� If you are concerned – consult your manager or IR function before trading.

Obligation to report inside information

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� If you become aware of information that could be price-sensitive and you are uncertain as to whether the information has been disclosed to the public through a press release, you are to immediately contact the person responsible for insider issues to report your knowledge of price-sensitive information.

�You may never disclose price-sensitive information to another person, whether outside or within the Actic Group.

Individuals covered by the policy

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�All individuals covered by Actic’s Insider Policy will individually be notified by the CFO and receive a copy of the Insider Policy.

�Permanent insider list includes persons who, through their position in the company, is deemed to have access to all undisclosed and price-sensitive information concerning the company, and responsible for informing the persons closely related to them of their obligations.

�Persons who only have access to undisclosed and price-sensitive information for a limited period of time are to be registered in the event-based insider list.

For full version of each policy, please see the following page on each of Actic’s respective local intranet.

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For full version of each policy, please see the following page on each of Actic’s respective local intranet.

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For full version of each policy, please see the following page on each of Actic’s respective local intranet.

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