H4-SV-19-A ut they are also the basis for our special compe Helical gear reducers H4

Flender/Flender Gear Units/Helical gear reducers H4

ficant impact on Flender such that, if disclosed, it represents insider information. Ultimately, Flender cannot make this decision for us. Furthermore, it is not the formal inclusion in an insider list that is decisive, but whether we are actually aware of insider information. Whether an insider list is opened and who is included in it should be viewed as separate decision to be made by the company. This also applies to insider information that con-cerns another company.Insider trading neither for us, nor for others! Insider information may not be used or disclosed without authorization. What is insider information? In our work, we often come into contact with confidential information. If it becomes known, some of this information may even be important enough to have material effect on Flender or another company, such as, for example, one of our publicly traded customers or suppliers, one of our sub-sidiaries or joint venture partner. This is called insider information as long as it has not yet been pub-lished. Insider information can also consist of many indi-vidual pieces of information that we have gained, for exam-ple, from discussions and docu-ments inside and outside the company or received incidentally. Our individual knowl-edge of the situation always matters. What is an insider and what are the consequences of being an insider? An insider is someone who has inside information. This person is subject to strict legal requirements. In almost all countries in which Flender operates, there are severe sanctions for the prohibited use of insider information. Such misuse could have considerable consequences for the company concerned and result in personal and crimi-nal liability. This is what we do: We do not engage in transactions based on insiderinformation, such as the purchase or sale of ashare or option or the cancellation of sharepurchase order, for us or for others. We do not induce others, such as friends or bankadvisors, to engage in securities tran