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Stora Enso's Insider Guidelines

The Company fully complies with the EU and Finnish regulation on market abuse as well as the insider guidelines of Nasdaq Helsinki. The Company’s internal insider guidelines are published and regularly distributed throughout the organisation. The Company expects all of its employees to act as required of an insider.

All unpublished information that relates to the Company’s present and future business operations must be kept strictly confidential.

Persons discharging managerial responsibilities (PDMR’s) in Stora Enso are the members of the Board, the CEO and the CFO, as well as the members of the Group Leadership Team (GLT). PDMR’s as well as their closely related persons are subject to a duty to notify the Company and the Finnish Financial Supervisory Authority of all transactions with the securities of the Company.

Closed Period List

The Company also keeps a list of persons that are involved in the preparation of interim reports and financial results, which is approved by the General Counsel. Persons included in the list are e.g. members of the Division management teams, the heads and all members of Communications and Investor Relations as well as the heads and certain team members of Treasury, Group Accounting and Controlling and Legal.

Insider Projects

Persons, who participate in the development and preparation of a project that constitutes inside information, are considered project-specific insiders. A separate project-specific insider register is maintained when considered appropriate by the General Counsel.

Trading Restrictions

The insider guidelines do not permit Stora Enso PDMR’s or persons involved in the preparation of interim reports or financial results to buy or sell any of the Company's securities (i.e. shares, options and synthetic options) during the closed period defined below or when they possess information that could have a material impact on the Stora Enso share price.

Closed Period

Stora Enso closed period starts when the reporting period ends or 30 days prior to the announcement of the results, whichever is earlier and lasts until the results are announced. The dates are published in the financial calendar. During closed periods Stora Enso PDMR’s or persons entered into the Company’s Closed Period List are not allowed to trade in Company securities.

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