Insiders' ownership

Nokia insider policy

The Board of Directors has established a policy in respect of insiders’ trading in Nokia securities. The members of the Board and the Nokia Leadership Team are considered as primary insiders. Under the policy, the holdings of Nokia securities by the primary insiders are public information, which is available from Euroclear Finland Ltd. and displayed in the table below.

Both primary insiders and secondary insiders (as defined in the policy) are subject to a number of trading restrictions and rules, including, among other things, prohibitions on trading in Nokia securities during the three-week “closed-window” period immediately preceding the release of our quarterly results including the day of the release, and the four-week “closed-window” period immediately preceding the release of Nokia’s annual results including the day of the release.

In addition, Nokia may set trading restrictions based on participation in projects. Nokia updates its insider trading policy from time to time and provides training for compliance with policy. Nokia’s insider policy is in line with the NASDAQ OMX Helsinki Guidelines for Insiders and also sets requirements beyond those guidelines.