Kempower Corporation’s shares are listed on Nasdaq Helsinki Ltd (“Nasdaq Helsinki”). When disclosing and publishing information, Kempower complies with the applicable EU and Finnish regulations and laws, the rules of Nasdaq Helsinki, the regulations and guidelines of the European Securities and Markets Authority and the Finnish Financial Supervisory Authority, as well as the company’s internal policies and guidelines.

The Board of Directors of Kempower Corporation has approved this Disclosure Policy to be applied in Kempower Corporation (including all its group companies, “Kempower” or the “Company”). The Disclosure Policy is reviewed and updated when deemed necessary. The internal and external procedures and principles related to communications and investor relations, which Kempower follows in its external communication, are defined in the Disclosure Policy. In addition, the responsibilities and obligations related to investor relations and communications are defined in the Disclosure Policy.

The Company’s communications follow the principle, according to which all relevant and accurate information shall be disclosed in a timely non-selective manner to all market participants. Any information disclosed must be correct, consistent, reliable, and timely and it must not be misleading.

2.1 Periodic Disclosure and Financial Reporting

Periodic disclosure obligation means the Company’s obligation to publish information regularly on the development of its results and financial position. It includes the publication of interim reports and financial statement releases as well as financial statements and the Board of Directors’ reports. They are the primary sources of information on the financial performance, balance sheet and financial position, outlook, development of profitability and other information related on these.

Kempower publishes annually an overview of Kempower’s business, including, among others, information on governance, compensation policies and practices as well as the annual financial information. In addition, Kempower publishes all other information required by the applicable laws and regulations.

Financial reporting under periodic disclosure obligation is published according to a previously announced schedule. The schedule is published before the end of the previous financial year and is available on the Kempower’s website.

2.2 Release Types

The releases published by the Company are divided into three categories: stock exchange releases, investor news and press releases. The type of release is determined based on the materiality and significance of the information and in accordance with applicable regulations.

2.2.1 Stock Exchange Releases

The Company publishes the information to be provided based on the periodic disclosure obligation and regular reports, and other releases to be provided based on the ongoing disclosure obligation (such as management’s share transactions, general meeting notices and general meeting resolutions), both as a stock exchange release.

Pursuant to the ongoing disclosure obligation, the Company shall primarily only publish separately regulated information as a stock exchange release and, insider information to be published under the Market Abuse Regulation ((EU) N:o 596/2014, “MAR”).

The Company publishes insider information as soon as possible with a stock exchange release, unless it has been decided to delay the disclosure of insider information in accordance with MAR and the Company’s Insider Guidelines.

Correspondingly, for example, business arrangements, acquisitions, investments and financing arrangements as well as decisions of authorities, which the Company considers having a significant effect on the value of the Company’s securities, are published as stock exchange releases.

2.2.2 Press Releases and Investor News

Releases directed to general or industry-specific media or investor news are used to provide information on events related to the Company’s business, which does not meet the requirements for stock exchange release but which are estimated to have news value or general interest among the Company’s stakeholders, such as, investor news or press releases on the following topics: product launches and advances on developing new technology, orders and contracts that are material for the Company, but taken as whole cannot be assumed to affect the valuation of the Company, the Company’s participation in a significant research and/or product development project, cooperation agreements as well as industry standards and technology development.

2.3 Distribution and Availability of Information

The goal is to ensure that all capital markets participant have in their possession, simultaneously and without delay, consistent, sufficient, and essential information about the essential matters related to the Company and its business operations which may affect the value of Kempower’s financial instruments, and that the disclosed information provides correct and sufficient information about the Company’s operations.

Kempower’s stock exchange releases are published in Nasdaq Helsinki and distribituted through a Newswire distribution network in accordance with the rules of Nasdaq Helsinki, in key media and on the Company’s website as simultaneously as possible. The Company also uses a variety of other means and channels for distribution of information, including press releases, magazines and publications, interviews, public presentations, public conference calls and web casts. The Company’s website www.kempower.com is the primary source of up-to-date information on Kempower. All releases and financial reports are available on the Company’s website for at least five years.

2.4 Language Versions

All information related the compliance of the Company’s disclosure obligation is published in Finnish and in English.

2.5 Responsibilities and Spokespersons

The Board of Directors approves the reports and releases under the periodic disclosure obligation as well as releases related to the disclosure of insider information. Releases related to other stock exchange information disclosure are approved by the CEO or CFO. Media releases and investor news are approved by the Vice President, Communications.

The CEO and the CFO shall have the authority to make public statements on behalf of Kempower on the Company’s strategy, finances, market development and demand, major strategic initiatives, and views of the Company.

Other members of Kempower’s leadership team and function leaders have the right to discuss matters related their area of responsibility within the limits set by this Disclosure Policy. In connection with publication of the releases, the person most familiar with the matter will be the official contact person and is entitled to discuss the matter at hand. The Vice President, Communication is primarily responsible for media relations.

2.6 Contacts with Media, Analysts and Other Stakeholders

Kempower regularly arranges meetings with analysts, investors, shareholders, and media.

In connection with the publication of financial reports, Kempower holds a press conference regarding the Company and its financial position, where it invites analysts and representatives of media. New or price sensitive information related to securities may not be disclosed in press conferences. Material used at the presentation shall be published on the Company’s website.

When the Company is being presented to capital market institutions, larger groups or in one-to-one meetings, either the CEO or CFO shall participate. To the extent possible, the Company is represented by at least two persons in presentations. The CEO, CFO and/or the person responsible for investor relations shall in advance of such meeting discuss what can and is intended to be discussed at such meeting. If price sensitive information is disclosed non-intentionally to a third party at such a meeting, such information shall be made public without delay.

2.7 Silent Period

Kempower does not arrange or participate in any meetings with media, analysts or investors during a silent period which begins at thirty days prior to the publication of a financial statement release or business reviews and continues until the publication of the financial statements or interim report for the reporting period. An exception to the rule is the publication of stock exchange releases regarding business events, in which case representatives of Kempower are allowed to answer questions related to disclosed event. Also in such cases, representatives of Kempower shall avoid commenting information included in the upcoming financial report.

2.8 Forecasts and Forward-looking Statements

Forward-looking statements shall always be presented in the yearly report by the Board of Directors, in the financial statement release and in the half-year report under a separate heading and shall be presented in as unambiguous and consistent manner as possible.

Where the Company may reasonably expect that its development will deviate significantly from a forward-looking statement, forecast or guidance previously published by the Company and such deviation is likely to have a significant effect on the price of the Company’s securities, the Company shall disclose information regarding the deviation as soon as possible. Such disclosure shall also reiterate the previous forecast or forward-looking statement.

2.9 Rumors, Market Speculation and Information Leaks

As a general policy, the Company does not comment on market rumors, speculation by the media, share price development, actions of competitors or customers or analyst calculations unless it is necessary to correct such clearly incorrect information that is likely to have a significant effect on the price of the Company’s securities. Neither will the Company comment on unpublished and unfinished business transactions, as long as the conditions for delaying disclosure are fulfilled.

If the Company learns that information that is likely to have a significant effect on the price of the Company’s securities, has leaked prior to its disclosure, or has been inadvertently disclosed to a third party not bound by confidentiality obligations, the Company shall publish a stock exchange release on the matter without delay.

Information leaks are prevented by maintaining insider registers, as necessary, by having nondisclosure undertakings in place, and by instructing and training personnel on insider issues. The Company has adopted insider guidelines which apply to all its employees, the Board of Directors and the CEO.

2.10 Crisis Communications

Kempower has written crisis management and crisis communication guidelines, which define the crisis management organization, the tasks and responsibilities of the crisis management team, and the crisis management plan.

To ensure the fulfilment of the Company’s disclosure obligations Kempower has established a Disclosure Committee. It is responsible for monitoring and interpretation of the Disclosure Policy. The Disclosure Committee addresses the general content of information to be published, including financial and other periodic and ongoing releases, and their timely disclosure and their compliance with regulatory requirements. The Disclosure Committee is comprised of the CEO, the CFO (Chair), the Vice President, Communications and the General Counsel.

In individual cases and for compelling reasons, the CEO has the right to deviate from the Disclosure Policy within the limits allowed by laws and regulations.