Finnair's public insider register consists of following persons with a duty to declare: Members of Board of Directors, CEO, auditors, deputy auditors and Finnair CEO's direct subordinates. Their securities ownership in Finnair is public.

Insiders Register

FINNAIR PLC'S INSIDER GUIDELINES

1. SCOPE OF APPLICATION AND PURPOSE
The Board of Directors of Finnair Plc (hereinafter "Finnair") has approved these insider guidelines. These guidelines shall be adhered to in all Finnair Group companies registered in Finland.
The purpose of these guidelines is to standardise and enhance the handling of insider issues within Finnair. These guidelines clarify and supplement the working practices of both the company and insiders, and act as a practical aid in the handling of insider issues.

These guidelines are binding on all personnel in the service of Finnair Group who are entered in the insider registers mentioned in these guidelines or who otherwise come into possession of insider information. Every person who comes into possession of insider information must keep confidential the information they receive and undertake to refrain from using such insider information.

2. DEFINITION OF A SECURITY
In these insider guidelines, by the term "security" is meant

• Finnair shares subject to public trading;
• securities (for example convertible bonds, stock options, option loans and subscription rights) granting entitlement to Finnair shares subject to public trading;
• securities granting entitlement to the securities mentioned above and
• other securities and derivatives contracts whose value is determined on the basis of a security referred to above

Insider information generally includes, among other things, information on:

• a merger or division of a company or other significant corporate arrangement;
• a share issue, a purchase or redemption offer or another change relating to the shares of a company, such as the lowering of the nominal value of the shares or the combining or division of share series;
• the contents of interim reports and financial statements.

Insider information may have connections with a number of companies, for example, when company A concludes a supply contract with company B and company C. The significance of the information shall be evaluated separately in each of these companies. It is possible that due to differences between the companies (differences in size, fields of operation), information on the contract shall be insider information with regard to the securities of company B, but not with regard to companies A and C.

Provisions relating to the use of insider information are divided into two groups. Chapter 5 of the SMA prohibits use and disclosure of insider information and Chapter 51 of the Penal Code has prescribed as a punishable act the abuse of insider information.

3.2 Definition of an insider
By the term insider is meant anyone who possesses insider information. The SMA divides insiders into primary and secondary insiders.

Primary insiders are people who have received insider information (i) as a shareholder of an issuer of securities, (ii) by virtue of their position, assignment or duties or (iii) through criminal activity.

Secondary insiders are any other people who possess insider information and who know or who should know that the information is insider information.

An insider can therefore by anyone, for example an outsider who gains knowledge of insider information by mistake.

3.3 Prohibition of the Securities Markets Act
Under the SMA an insider must not

• use insider information by acquiring or transferring on his or her own or on another person's account, directly or indirectly, securities affected by the information;
• advise directly or indirectly another person in the trading of such securities; nor
• disclose insider information to another person, if this does not take place as part of the ordinary performance of the work, profession or duties of the person disclosing the information. In such cases, there must be for the disclosure of information an acceptable reason as far as the company in question is concerned and the recipient of the information must be aware that the information he or she receives is confidential.

The Financial Supervision Authority may impose on an individual who violates the provisions of the SMA a public caution or warning. In addition, the Market Court may on the proposal of the Financial Supervision Authority impose a fine, if a public warning is not considered sufficient.

3.4 Prohibitions of the Penal Code
The abuse of insider information is punishable under Chapter 51 Section 1 of the Penal Code.

Anyone who in order to gain financial benefit for him/herself or another or through gross negligence makes use of insider information relating to a security subject to public trading

• by transferring or acquiring such a security on his or her own behalf or on behalf of another; or
• by advising directly or indirectly another party in a transaction relating to the security shall be sentenced for the abuse of insider information to a fine or to imprisonment not exceeding two years.

4. FINNAIR'S INSIDERS
4.1 General
Finnair's insiders are divided into permanent insiders and temporary insiders.

Permanent insiders are further divided into those entered in a public insider register and those entered in a non-public company-specific insider register.

Temporary insiders are individuals who receive insider information during the performance of some assignment (project). These individuals are entered into a non-public company-specific insider register, namely a project-specific register.

4.2 Public insider register
4.2.1 Ordinary persons with a duty to declare
Persons with a duty to declare are Finnair's

• Chairman and Deputy Chairman of the Board of Directors
• Members and Deputy Members of the Board of Directors
• Chief Executive Officer
• Acting Chief Executive Officer
• Auditor
• Deputy Auditor
• the person, employed by an auditing firm, who has main responsibility for Finnair's auditing as well as those individuals in an expert position who assist the auditor with main responsibility in the auditing process
• other senior management personnel who regularly receive insider information and who have the right to make decisions on Finnair's future development and business arrangements.

Ordinary persons with a duty to declare belong to Finnair's public insider register and their securities ownership in Finnair is public. They are covered by prohibitions on the use, disclosure and abuse of insider information as well as the restriction on trading referred to in item 5.

4.2.2 The immediate circle of a person with a duty to declare
In addition to ordinary persons with a duty to declare mentioned in item 4.2.1, individuals and organisations belonging to the immediate circle of persons with a duty to declare also have a duty to declare. The immediate circle of ordinary persons with a duty to declare are:

• the spouse or registered partner of a person with a duty to declare, as referred to in the Act on Registered Partnerships, but not, however, a common-law wife/husband
• an individual under the guardianship of a person with a duty to declare
• other family members who have lived in the same household with a person with a duty to declare for at least one year (relatives referred to in Chapter 2 of the Inheritance Code, such as children, grandchildren and parents)
• a company or foundation controlled directly or indirectly by the individual mentioned above solely or jointly with a family member or with another person mentioned in the paragraph above or members of that person's family (hereinafter "controlled corporation")

• information about themselves
• information about their spouse (husband/wife or registered partner referred to in the Act on Registered Partnerships)
• information about people under their guardianship
• information about other family members who have lived in the same household with the person with a duty to declare for at least one year (relatives referred to in Chapter 2 of the Inheritance Code, such as children, grandchildren and parents)
• information about controlled corporations described in item 4.2.2 above
• information about companies and foundations in which the person with a duty to declare, his/her spouse or other family member who has lived in the same household for at least one year has influence (hereinafter "influence corporation"); and
• in the event that the individuals and controlled corporations stated above own securities issued by Finnair or by a company belonging to the Finnair Group and which are not book entry shares, the ownerships of the said securities (Basic declaration, Form 2).

Declarations should be sent to the person responsible for managing Finnair's insider registers, at the address Finnair Plc, HEL AAC/6, 01053 Finnair. Persons with a duty to declare are responsible for fulfilling their duty to declare also when the management of their securities has been entrusted to another party.

By beginning a task is meant the date when the individual actually begins to work on the task (for example as Chief Executive Officer or as a Member of the Board of Directors). Mere selection for the task does not immediately impose a duty to declare.

A duty to declare affects a deputy auditor in so far as he/she has accept the auditing assignment. A deputy auditor is a person with a duty to declare until the Annual General Meeting has selected a new regular auditor and he/she has accepted the assignment. If the regular auditor is an auditing firm and the deputy auditor is employed by the firm in question, the deputy auditor's duty to declare begins at the same time as the regular auditor's duty to declare begins.

Persons with a duty to declare do not need to declare as controlled or influence corporations the following Finnish or corresponding foreign organisations:

• subsidiaries of Finnair Plc
• housing corporations
• real estate corporations
• societies, such as sports and hobby clubs, student organisations and trade unions
• economic associations, such as forest management associations, road maintenance associations and fishery associations.

An auditor, deputy auditor or auditing firm employee who has main responsibility for the company's auditing does not need to declare as influence corporations those corporations in which their influence is based on their auditing tasks.

4.2.3.2 Declaration of changes
In the event of information given in the basic declaration changing, persons with a duty to declare must make a declaration of the change in the information within seven (7) days, using the forms issued by the Financial Supervision Authority. The declaration should be delivered to the person managing Finnair's insider registers.

In terms of a new child of persons with a duty to declare, the 7-day period for declaring a change begins from the time the child is entered in the population register.

The duty to declare relating to a new controlled corporation begins when the corporation has been entered in the Trade Register.

As the registration of holdings and any changes therein varies in different situations, different actions are required from persons with a duty to declare as follows:

• Changes relating to securities incorporated in the book-entry system shall be automatically entered in the SIRE system of Finnish Central Securities Depository Ltd when the transaction has been concluded on the Helsinki Exchanges. A separate declaration of such changes in holdings need not be submitted.
• When a change relates to securities incorporated in the book-entry system, but the transaction or other change (e.g. exchange, gift or inheritance) relating to securities incorporated in the book-entry system has been concluded outside the Helsinki Exchanges, persons with a duty to declare must ensure that they make a change declaration and that the change is entered to the appropriate book-entry account of the book-entry register.
• When a change relates securities other than those in the form of book entries (for example derivatives contracts), persons with a duty to declare must make a change declaration (see footnote 3). In terms of derivatives contracts, a change declaration must be made both when a contract is made and when its validity has expired.

4.2.5 Maintaining the public insider register
Finnair's public insider register is available to the public at the internet address of the Euroclear Finland Oy NetSire service: www2.apk.fi/NewNetSire/index.jsp. The service can also be accessed via Finnair's website www.finnair.fi.

The personal ID numbers and addresses of natural persons as well as the names of natural persons other than those persons with a duty to declare are not, however, public.

The company has nominated a person responsible for the insider register, who produces guidelines for the register and ensures that it is reliably maintained and published.

4.3 Company-specific insider register
4.3.1 General
In accordance with the Securities Markets Act, Finnair maintains a company-specific insider register, which is divided into a subregister holding permanent insiders and separate project-specific registers. Rules relating to project-specific insider registers are outlined in section 6 of these guidelines.

4.3.2 People entered in the permanent company-specific insider register
In accordance with the Securities Markets Act, the following individuals must be entered in the company-specific insider register:

• individuals in the company's service who by virtue of their position or duties regularly receive insider information
• other individuals who on the basis of an employment or other agreement work for the company and receive insider information
• individuals belonging to company bodies who receive insider information

The following individuals in the company's service belong to the permanent company-specific insider register:

• Personnel representatives participating in the work of Finnair's Management Group
• The managing directors of Amadeus Finland Oy, Matkatoimisto Oy Area, Suomen Matkatoimisto Oy, Oy Aurinkomatkat - Suntours Ltd Ab, Finnair Travel Services Oy, Finnair Facilities Management Oy and Finnair Aircraft Finance Oy.
• The secretaries of Finnair's Chief Executive Officer, Chief Financial Officer and Senior Vice President, Administration and Human Resources
• Finnair's lawyers and internal auditors
• Finnair's financial communications officers, economics and finance directors and assistant directors, controllers, finance managers, and the planning manager, financial management and control
• Vice Presidents of Finnair's Commercial Division and Vice President, Leisure Flights
• Department Directors, Employment Affairs and HR Services
• Other individuals that Finnair's Chief Executive Officer separately designates be entered in the register

They are not obliged to declare their securities holdings nor information on their immediate circle to the insider register. The company-specific insider register is not public.

4.3.3 Maintaining the permanent company-specific insider register
Finnair maintains its company-specific register of insiders in the SIRE system of Finnish Central Securities Depository Ltd. The company-specific insider register is not available to the public.

The information listed in the Securities Markets Act in terms of the individuals belonging to the permanent company-specific insider register is entered in the company-specific insider register. The insider register is always updated when the basis for an individual's entry changes, a new individual is entered in the register, and an individual who is entered in the register no longer receives insider information.

Individuals entered in the company-specific insider register are notified in writing or otherwise verifiably about their entry in the register and the obligations arising from this.

The person managing Finnair's insider registers maintains the permanent company-specific insider register, produces guidelines for the register and ensures that it is reliably maintained.

5. RESTRICTION ON TRADING
5.1 Closed window
Permanent insiders (individuals entered in the public insider register and in the permanent company-specific insider register) shall schedule their trading of securities issued by Finnair so that such trading does not undermine confidence in the securities markets.

Finnair's permanent insiders must not trade in securities issued by the company in the 30-day period before the publication of the company's interim reports and financial statement bulletins (closed window). The prohibition on trading shall end when the interim report or financial statement bulletin has been published. Before beginning to trade, an insider must ensure that the interim report or financial statement bulletin has been published. The restriction on trading shall also apply to standardised derivatives contracts and derivatives contracts comparable to them as well as other derivatives contracts, the underlying asset of which is the Finnair share or a security granting entitlement to the share under the Companies Act.

The company may, if necessary, also prescribe other restrictions on trading.

5.2 Area of application of the restriction on trading
The restriction on trading shall apply to Finnair's permanent insiders (individuals entered in the public insider register and in the permanent company-specific insider register) as well as to those under their guardianship and to controlled corporations.

Permanent insiders are also responsible for complying with the restriction on trading when the management of their securities has been assigned to another person.

The restriction on trading shall not apply

• when acquiring securities by subscription or by some other means directly from the company or from a company belonging to the same group
• when acquiring securities as a redemption, merger or demerger consideration or as a consideration in accordance with a public offer or in another comparable manner
• when acquiring securities as a dividend or as other distribution of the company's profit
• when acquiring securities as remuneration for work or other corresponding performance or service
• when acquiring securities as an inheritance, under a will, as a gift or in a distribution of marital assets or in some other comparable way.

The prohibition on the use, disclosure and abuse of insider information shall apply also when a derogation from the restriction on trading is in effect.

6. PROJECT-SPECIFIC REGISTER OF INSIDERS
6.1 Project
A project is deemed to be an individualisable entity or arrangement subject to confidential preparation which, when realised, is likely to have a material effect on the value of a security issued by Finnair for public trading and which contains insider information.

A project is typically an entity or arrangement which due to its nature or size differs from the usual business operations of the company. Measures directed at the company on the initiative of another party and in which the company is not involved shall not constitute a project from the point of view of the company. The company shall evaluate on a case-by-case basis whether an entity or arrangement under preparation shall be deemed a project.

The evaluation shall be made as a case-by-case comprehensive evaluation, taking into consideration all factors relevant to the matter. These facts may be both internal with regard to the company (e.g. the decision-making process in the company necessary for the realisation of the entity or arrangement under preparation as well as the importance of the arrangement for the company) or external (e.g. the established corporate practices of the company's line of business). Previous corporate practice shall be consistently taken into consideration in the evaluation. The evaluation shall be based on the information available at the time in question. Should the significance of the information forming the basis of the evaluation change later on, the company shall re-determine whether the entity or arrangement is deemed to be a project.

6.2 Project evaluation criteria
The following criteria, among others, can be used when evaluating whether an entity or arrangement should be deemed a project:

• The entity or arrangement is such that when realised it must be published on the basis of a duty to provide information continuously;

A duty to publish information does not as such mean that the decision or issue that is subject to the duty to publish information shall be deemed a project. For example, a dividend distribution proposal, future development prospects, or changes in financial performance and in the balance-sheet or financing position, which are published on the basis of a duty to provide information continuously, shall not be deemed a project.

Issues subject to a duty to provide information regularly, e.g. interim reports or the financial statements, shall not be deemed projects.

If the company makes public that a certain entity or arrangement is under preparation by the company, this entity or arrangement shall generally no longer be deemed a project.

• The preparation of an entity or arrangement has progressed to the stage where a decision has been made by the management of the company to continue preparation until realisation.

• If the situation involves an entity or arrangement whose realisation requires the cooperation of another party, it is generally appropriate to deem such a situation a project only after the said party has begun preparations aimed at realising the entity or arrangement.

• The realisation of an entity or arrangement is probable.

• The estimated realisation time of the entity or arrangement under preparation is in the near future.

In addition to the above criteria, the company shall make an assessment of the entity or arrangement as a whole when determining whether it shall be deemed a project.

On the basis of an overall assessment, the company may deem the entity or arrangement a project, even if all of the above criteria are not fulfilled.

6.3 Management of project-related insider information
The person responsible for the preparation of a matter that contains insider information must contact Finnair's legal affairs department to set up a project-specific insider register. The decision to set up a project-specific insider register shall be made jointly by the person responsible for preparing the matter and Finnair's senior lawyer.

When the company defines an entity or arrangement under preparation to be a project, a project-specific register of insiders shall be prepared for it in the SIRE system of Finnish Central Securities Depository Ltd. At the same time, a person shall be assigned to manage the project-specific register. If possible, Finnair's Board of Directors shall make the decision on the setting up of a project-specific insider register. The members of the Board of Directors shall in that case be entered in the project-specific insider register.

A project-specific register of insiders should include at least the following information:

• the register establishment date and the person managing the register
• the project (for example code name), to which the register relates
• the name, social security number and nationality of the individuals to whom information about the project has been given (in terms of an individual from outside Finnair, the company or official body which the individual represents shall also be included)
• the justification for why the individual is entered in the register
• the date and time when the project-specific insider has received information about the project
• the termination of the project as a result of either publication or expiration as well as the date of termination
• any other relevant project information.

Individuals entered in a project-specific insider register are notified in writing or otherwise verifiably about their entry in the register and the obligations arising from this. A project-specific insider must keep confidential all project-related information. A project-specific insider is a primary insider referred to in item 3.2 and is covered by the prohibition on the disclosure of insider information. Only the person responsible for a project has the right to decide on the disclosure of insider information under the terms mentioned in item 3.2. The person responsible for a project and person who discloses insider information are responsible for ensuring that the individual to whom the information has been disclosed is entered immediately in the project-specific insider register.

A project-specific insider register exists for a designated term. A project ends as a rule on the publication of the project, but it can end in other ways. The person responsible for a project must always inform Finnair's legal affairs department about the ending of the project. Those entered in a project-specific insider register must also always be informed about the ending of the project.

6.4 Restrictions and legal effects relating to projects
Finnair shall issue instructions on the trading practices of project-specific insiders and the timing of their transactions so that abuse of insider information is avoided.

Where the company has deemed an entity or arrangement under preparation to be a project and has prepared a project-specific insider register for it, it shall usually be necessary to prohibit those entered in the register from trading in Finnair securities until the expiration or publication of the project.

The instructions relating to the trading practices of project-specific insiders or the timing of their transactions may also apply to trading in securities of another company as well as to general confidentiality. Project participants are usually also required to make a separate written confidentiality undertaking.

If a project is directed at another listed company (e.g. a significant corporate acquisition where the target is a listed company), the company shall generally be justified in prohibiting project-specific insiders from trading in the securities of the other company.

The restriction on trading based on a project-specific register shall enter into force from the moment the project-specific insider has been notified of the restriction. Irrespective of the beginning of a restriction on trading, insiders shall be responsible for ensuring that they comply with the appropriate laws, regulations and guidelines.

Those entered in a project-specific insider register are covered by the prohibitions on the use, disclosure and abuse of insider information. Prohibitions are valid until the project results have been reported or it has otherwise ceased to be insider information.

Those entered in a project-related insider register are not obliged to declare their securities holdings nor information on their immediate circle to the insider register. A project-specific insider register is not public.

7. MANAGEMENT OF INSIDER ISSUES
7.1 Communication
Finnair shall make these guidelines available to the permanent insiders of the company on the company's intranet and on its internet website. Everyone in the service of the Finnair Group is personally responsible for ensuring that they have registered as an insider and have made the appropriate insider declarations. The line manager of individuals entered in the company-specific insider register is obliged to notify the person managing the insider registers of the beginning and end of such individuals' employment.

7.2 Tasks of insider management
Finnair's insider management shall include the following tasks:

• the company's internal communication on insider issues
• training in insider issues within the company
• maintaining the public insider register
• maintaining the permanent company-specific insider register
• preparing and maintaining the project-specific registers
• supervising insider issues

As part of its insider management, Finnair has instituted a procedure in which insiders may ask for an assessment as to whether security trading transactions they are planning comply with these guidelines and the law. The assessment is given by Finnair's legal affairs department on the basis of information supplied by the insider and information otherwise available at the time the assessment is made. Notwithstanding the assessment procedure, the insiders themselves are responsible for ensuring that they comply with laws, regulations and guidelines.

8. SUPERVISION
The information in the public insider register and permanent company-specific insider register shall be checked annually. The person responsible for managing Finnair's insider registers shall ensure that the check is performed.

The company shall check at least once a year the trading of the permanent insiders, based on the register information of the Finnish Central Securities Depository Ltd. The person responsible for managing Finnair's insider registers shall ensure that the check is performed. The company shall, if necessary, supervise in more detail on a case-by-case basis the trading of securities of its permanent insiders if a permanent insider trades in large volumes of securities or continually engages in securities trading.

The Financial Supervision Authority shall monitor that the obligations mentioned in these guidelines are obeyed.

Should anyone in a service or employment relationship with the Finnair Group violate the rules mentioned in these guidelines, the person responsible for managing Finnair's insider issues has the right to issue the individual with a written caution as a result of the violation. In addition, the employer may, depending on the nature of the violation, issue a warning or notice of termination or may cancel the service or employment contract.

The Financial Supervision Authority may impose on an individual who violates the provisions of Chapter 5 of the SMA a public caution or warning about the use or disclosure of insider information. In addition, the Market Court may on the proposal of the Financial Supervision Authority impose a fine, if a public warning is not considered sufficient. If the case involves the abuse of insider information described in the Penal Code, the outcome may be a fine or imprisonment.

The Financial Supervision Authority may impose a fixed penalty on a party who neglects to make an insider notification or fails to maintain an insider register.

9. PROVISIONS ON WHICH THESE GUIDELINES ARE BASED
These guidelines are based on the following Finnish statutes, standards and guidelines:

• The Securities Markets Act
• The Act on Trade in Standardised Options and Futures
• The Financial Supervision Act
• The Penal Code
• The Financial Supervision Authority's standard for insider declarations and registers
• The insider guidelines of the Helsinki Exchanges