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Insider management

Pandox complies with the EU Market Abuse Regulation (MAR) and the Board of Directors has adopted an insider policy with rules and instructions for compliance with the regulation. The policy is continuously updated and internal training on its content is held regularly for those concerned. Pandox maintains a list of "persons discharging managerial responsibilities" (members of the Board of Directors and members of Group Management) and natural and legal persons related to them, as defined by MAR.

Persons discharging managerial responsibilities may not trade in Pandox's shares (or share-related instruments such as subscription rights, interim certificates, convertibles, warrants, futures, etc.) or debt instruments for 30 calendar days prior to the publication of an interim report or a year-end report.

Persons discharging managerial responsibilities and related legal or natural persons shall report transactions in Pandox's financial instruments to Pandox and to the Swedish Financial Supervisory Authority. The notification shall be made as soon as possible and no later than three business days after the date of the transaction.

Members of group management and certain others, members of the Board of Directors excluded, may not acquire or dispose of financial instruments issued by (or related to) Pandox without the prior approval of Pandox's IR manager.