Lemminkäinen Group's Disclosure Policy

Lemminkäinen Group's parent company, Lemminkäinen Corporation, is domiciled in Helsinki, Finland, and its share is listed on Nasdaq Helsinki Ltd ("Nasdaq Helsinki"). In our communication and disclosure we comply with applicable Finnish and EU legislation, the rules of Nasdaq Helsinki, the regulations and guidance of the European Securities Markets Authority (ESMA) and the Finnish Financial Supervisory Authority, as well as our internal policies and guidelines.

Our communications is based on facts and objectivity, and guided by the general principles of trustworthiness, consistency, openness and timeliness. The President and CEO is responsible for that we meet our obligations as a listed company.

Key principles of communications

Financial reporting units. The Group as a whole and Lemminkäinen's reportable business segments are the only units that externally report financial information and key figures.

Financial reporting schedule. The financial statements bulletin, half year financial report and two interim reports are published according to a previously announced schedule. The schedule is published before the end of the previous financial year and is available on our website.

Financial reporting. We give information on the financial performance, balance sheet and financial position, outlook, profitability trend and other similar matters primarily in the financial statements bulletin, half year financial report and interim reports. We also publish an annual report, which includes an annual review, the Board of Directors' report, financial statements and the corporate governance statement.

Guidance. In the financial statements bulletin, Board of Directors' report, half year financial report and in the interim reports we provide general guidance on how demand and the market will develop in the near future, and give an assessment of the key factors and risks affecting future development. We also give an assessment of our net sales and profitability development for the current year.

Profit warning. We issue a profit warning as soon as possible if we reasonably expect that the outlook changes from the previously released guidance or the Group's profitability or financial position improves or weakens more than can reasonably be expected and such deviation is likely to have a significant effect on the price of the Company's financial instruments. A profit warning is always issued as a stock exchange release.

Public releases. We disclose as soon as possible a stock exchange release describing any fact, issue or event that we believe will have a significant effect on the price of the Company's shares or other financial instruments. A stock exchange release is also used to publish regulated information that is required to be disclosed by means of a stock exchange release (such as management transactions, notices to general meetings and resolutions of the same), even if such releases do not normally include price-sensitive information.

Issuing a stock exchange release generally follows the review and determination of an obligation of disclosure. This review is conducted simultaneously with the process of assessing the prerequisites to delay disclosure, if relevant.

In addition, news that do not meet the requirements set for stock exchange releases but are nonetheless regarded by us as being newsworthy or of general interest to our stakeholders are published as investor news or press releases or on our website. Our significant development and construction projects are generally published when the decision to start the project has been made. Significant contracting projects are generally published once the agreement has been signed, or in public tendering, once the decision has been published. Some contracting projects can remain confidential if agreed so with the customer. If these projects are significant for our business segments, they are generally followed up in our interim reports.

Communication practices

Distribution and availability of releases. The principal source of up-to-date information on Lemminkäinen is our website, www.lemminkainen.com. Corporate Communications is responsible for the website and for the production, publication and distribution of Lemminkäinen's releases. Lemminkäinen's stock exchange releases are simultaneously published to Nasdaq Helsinki, disseminated through a newswire distribution network in accordance with the rules of Nasdaq Helsinki and automatically filed in the Central Storage Facility of Regulated Information, key media, and on our website. All of Lemminkäinen's releases and financial reviews are available on the website for at least ten years.

Reporting language. Our official reporting language is Finnish. All material under disclosure obligation of a listed company is published in English as well.

Meetings with investors, analysts and media representatives. We regularly meet with representatives of the capital markets and the media, and responds to their inquiries as quickly as possible.

We have separate Investor Relations principles that determine the responsibilities and operation models for investor relations. All meetings with equity analysts and investors are centrally co-ordinated. Group Treasury co-ordinates meetings with credit analysts and investors together with the CFO. Corporate Communications co-ordinates the meetings with representatives of the financial and other media.

All meetings are based on information that has already been published or is generally available to the market. New information that might affect the price of the Company's financial instruments is not introduced at these meetings.

Spokespersons. Statements concerning the operations and development of Lemminkäinen Group are made mainly by the President and CEO and the CFO. The executives and experts of the business segments, support functions and business areas give statements on matters within the scope of their own areas of responsibility.

Silent period. We observe a silent period prior to publication of our financial results. The silent period begins at the end of each quarter and applies until the publication of the half year financial report, interim report or the financial statements bulletin. The silent period shall, however, always include at least 30 calendar days immediately preceding the publication of the half year financial report, interim report or financial statements bulletin, as the case may be. During this period we do not discuss or comment on the result, financial position, or outlook of the Group or the business segments. Group management, or Group Treasury function do not meet with representatives of the capital markets or financial media during the silent period.

Exceptions to this rule are the annual general meetings of shareholders (if held during the silent period) and the publishing of a stock exchange release regarding a significant business event and the related communication; however, such communication will be limited to the relevant event only.

Rumours, market speculations and information leaks. We do not comment on any market rumours, speculations by the media, the development of the share price, the actions of competitors or customers, or the forecasts of analysts unless it is necessary to correct clearly erroneous specific information that is likely to have a significant effect on the price of the Company's financial instruments. We will not either comment on unpublished and unfinished business transactions, as long as the conditions for delaying disclosure are fulfilled.

If confidential information that is likely to have a significant effect on the price of the Company's financial instruments leaks out prior to public disclosure, we publish a stock exchange release concerning the matter as soon as possible.

Crisis communications. Crisis situations are reported to the Group Executive Team and the Board of Directors. Depending on the extent and nature of the crisis, a crisis team may be appointed. If needed, a crisis communications team is assembled to handle both internal and external communications during the crisis. The Head of Group Communications and Marketing or a person she/he has appointed leads the crisis communications team. The crisis communications team's task is to ensure that information is openly available and that it is consistent and reliable.

Insider rules. We have adopted internal insider rules approved by the Board of Directors, which apply to all our employees, executives and directors. Insider administration is described on Lemminkäinen's website.

Interpretations and deviations. The Company's President and CEO is responsible for supervising Lemminkäinen's disclosure policy and deciding on any possible deviations from it.

Originally approved by the Board of Directors on 5 May 2010. Reviewed and updated on 28 March 2016.