Aspo Oyj — Governance Information 2026

Mar 24, 2026

GOVERNANCE

2025

ASPO

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ASPO
CORPORATE GOVERNANCE STATEMENT 2025

GOVERNANCE

Corporate Governance Statement

Aspo Plc is a Finnish publicly listed company. Its objective is to increase the shareholder value responsibly in the long term by leading and developing the businesses it owns.

ASPO'S GOVERNING PRINCIPLES

Aspo's decision-making and governance comply with the Finnish Limited Liability Companies Act, securities markets legislation and regulations concerning listed companies, Aspo Plc's Articles of Association, and the rules and regulations of Nasdaq Helsinki Ltd.

Aspo complies with the Finnish Corporate Governance Code that entered into force on January 1, 2025, which is available on the Securities Market Association's website at www.cgfinland.fi.

In addition to this statement, Aspo Plc has published a separate Board of Directors' Report 2025, which is included in the Annual Review. This statement will not be updated during the financial year, but the information about the topics included in it, as well as other necessary and up-to-date information for investors, is available on the company's website at www.aspo.com.

The Corporate Governance Statement, the company's financial statements, the Board of Directors' Report, and the auditor's report are all available on Aspo's website at www.aspo.com.

GROUP STRUCTURE

Aspo Group's parent company, Aspo Plc, is a Finnish public limited company domiciled in Espoo. The main responsibility for Aspo Group's administration and operations lies with Aspo Plc's governing bodies: the General Meeting, the Board of Directors, and the CEO. The highest decision-making power is exercised by the shareholders at the General Meeting. The Board of Directors and the CEO are responsible for the management of Aspo Group. The Audit Committee and the Human Resources and Remuneration Committee support the Board of Directors' work. The Group Executive Committee assists the CEO in managing Aspo Group.

ANNUAL GENERAL MEETING

The Annual General Meeting is held every year on a date determined by the Board of Directors, and it deals with matters falling within the competence of the Annual General Meeting based on the Articles of Association, the proposals of the Shareholders' Nomination Board and the Board of Directors, and other possible proposals to the Annual General Meeting. The Annual General Meeting, among other things, adopts the financial statements, elects the Board members, the auditor of the financial statements, and the assurance provider of the sustainability statement, and decides on profit distribution and the remuneration of the Board members, auditor, and sustainability statement auditor.

According to the Limited Liability Companies Act, a shareholder is entitled to have a matter falling within the competence of the Annual General Meeting dealt with by the Annual General Meeting if the shareholder so requests in writing from the Board of Directors well in advance, so that the matter can be included in the notice of the meeting. When required, an Extraordinary General Meeting is convened. The Board of Directors must also convene an Extraordinary General Meeting if an auditor or shareholders

with a total of at least 10% of all shares so request in writing, in order for a given matter to be dealt with.

The Board of Aspo Plc convenes the General Meeting. The notice of the meeting is published by means of a stock exchange release and on the company's website no earlier than two months and no later than twenty-one (21) days prior to the meeting, but at least nine (9) days prior to the record date of the General Meeting. In addition, the Board of Directors may, at their discretion, decide to announce the Annual General Meeting in one or several newspapers. In addition, the following information is published on the company's website no later than 21 days before the Annual General Meeting:

• The total number of shares and voting rights by share class on the date of the notice of the meeting
• Documents to be presented to the General Meeting
• Decisions proposed by the Board of Directors or other competent body
• Any matter that is included in the agenda of the General Meeting but for which no decision is proposed

The decisions of the General Meeting are published after the meeting by means of a stock exchange release. The minutes of the General Meeting, with the possible voting results and appendices related to the decisions, are published on the company's website within two weeks of the General Meeting.

SHAREHOLDERS' NOMINATION BOARD

Aspo Plc has a Shareholders' Nomination Board that prepares proposals to the Annual General Meeting regarding the election and remuneration of the Board members and the remuneration of the Board's committees. Aspo's Shareholders' Nomination Board consists of the representatives of the four largest shareholders. In addition, the Chair of

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ASPO
CORPORATE GOVERNANCE STATEMENT 2025

Board of Directors of Aspo acts as an expert member of the Nomination Board.

The following representatives of the largest shareholders were members of the Nomination Board that prepared proposals for the 2025 Annual General Meeting: Roberto Lencioni, Chair (Vehmas family, including AEV Capital Holding Oy, gender: male); Gustav Nyberg (Nyberg family, including Oy Havsudden Ab, gender: male); Pekka Pajamo (Varma Mutual Pension Insurance Company, gender: male) and Karoliina Lindroos (Ilmarinen Mutual Pension Insurance Company, gender: female). In addition, Heikki Westerlund, Chair of Aspo's Board of Directors, has served as an expert member of the Nomination Board.

The Shareholders' Nomination Board convened four times during 2025. The attendance rate at the meetings was 100 percent.

BOARD OF DIRECTORS

The Board of Directors is responsible for the administration of Aspo and the appropriate organization of its operations. The Board of Directors has established an Audit Committee and a Human Resources and Remuneration Committee to support its work. When required, the Board of Directors can establish other permanent or temporary committees.

According to the Articles of Association, Aspo Plc's Board of Directors consists of five to eight members.

The number of members of the Board is decided by the General Meeting, where its members are also elected. The Board of Directors elects a Chair and a Vice Chair from among its members. At the Annual General Meeting 2025, seven members were elected. The term of the members ends upon the conclusion of the next Annual General Meeting following the election.

The Board constitutes a quorum when more than half of the members, including either the Chair or the Vice Chair are present. The Board of Directors seeks to make unanimous decisions, but matters are put to a vote when required and the decisions are made by a majority of votes. In the event of a tie, the Chair has the casting vote.

The Board of Directors convenes regularly, and whenever necessary.

The duties and responsibilities of the Board of Directors are set out in the Articles of Association, the Finnish Limited Liability Companies Act, and other applicable legislation. The particular duty of the Board of Directors is to promote the interests of the shareholders and the company by taking care of strategic policy decisions and the appropriate organization of business operations and administration, for example. The Board of Directors is also responsible for ensuring that the supervision of the company's accounting and asset management has been appropriately organized. The Board of Directors processes and decides on all matters concerning the company's operations that are most significant for the company. The Board of Directors has competence in all matters that are not handled by other administrative bodies pursuant to law or the Articles of Association.

Aspo Plc's Board of Directors has confirmed written standing orders, which state that the matters to be handled by the Board include, but are not limited to, the following:

• Aspo Group's strategic guidelines and the strategies of its businesses
• Group structure
• Matters to be presented to the General Meeting
• Interim reports and consolidated financial statements
• The Group's business plans, budgets and investments
• Expanding and scaling back operations, acquisitions/ divestments of companies or operations
• Group risk management, insurance and financial policies
• Group environmental policy

• Management remuneration and incentive plans

• Appointment of the CEO

• Monitoring the financial and financing situation of Aspo Group and
• Monitoring and evaluation of the company's sustainability reporting process and assurance

The Board carries out an annual self-evaluation of its operations and working methods.

The Board of Directors had 18 meetings in 2025. The attendance rate was 100%.

Aspo's Board members are independent of the company, and the majority of the members are independent of Aspo's major shareholders.

Board committees

The Board of Directors may establish committees or other permanent or temporary bodies to carry out tasks determined by the Board in compliance with its standing orders. The committees do not have independent decision-making power, but the Board makes decisions based on the preparation of the committees. The Board of Directors elects the members of each committee and appoints its Chair. The Board of Directors confirms the standing orders for each committee, specifying the key tasks and operating principles of the committee. The majority of members of each committee must be independent of the company, and at least one member must be independent of the company's major shareholders. The members of committees must have the competence required for the range of tasks handled by the committee concerned. The diversity of competence, experience, and views of the committee members should support professional handling of matters and open discussion, and should promote the committee's ability to evaluate matters in its area of responsibility in a versatile manner.

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ASPO
CORPORATE GOVERNANCE STATEMENT 2025

Audit Committee

The Audit Committee is responsible for preparing matters related to the company's financial reporting and control. With the regulatory changes in sustainability reporting, the tasks of the Audit Committee have expanded since 2024 to include supervision and monitoring tasks related to sustainability reporting. The Audit Committee consists of the Chair and at least two members, whom the Board appoints from among its members for one year at a time. In 2025, Kaarina Ståhlberg served as Chair of the Audit Committee, with Annika Ekman, Mikael Laine, and Tatu Vehmas as its members.

The duties of the Audit Committee include:

• Monitoring the financial statements reporting process
• Supervising the financial reporting process
• Assessing the use and presentation of alternative performance measures
• Monitoring the effectiveness of internal control and audit and risk management systems, including digital reporting and sustainability reporting
• Reviewing the plans and reports of the internal audit function
• Reviewing the plans and reports of the company's compliance function
• Handling of the company's corporate governance statement and non-financial report
• Monitoring the statutory audit of the financial statements and the consolidated financial statements
• Assessing the independence of the auditing firm
• Assessing the ancillary services provided by the auditing firm
• Preparing the proposal for the appointment of the auditor
• Communicating with the auditor in addition to the duties required by regulations

THE BOARD AND COMMITTEE MEMBERS ATTENDANCE IN MEETINGS IN 2025

	Board member since	Committee membership	Board	Audit Committee	Human Resources and Remuneration Committee
Heikki Westerlund	2021	Human Resources and Remuneration Committee (Chair)	18/18		5/5
Mikael Laine	2016	Audit Committee	18/18	6/6
Patricia Allam	2022	Human Resources and Remuneration Committee	18/18		5/5
Annika Ekman	2025	Audit Committee	18/18	5/6
Tapio Kolunsarka	2023	Human Resources and Remuneration Committee	18/18		4/5
Kaarina Ståhlberg	2024	Audit Committee (Chair)	18/18	6/6
Tatu Vehmas	2018	Human Resources and Remuneration Committee as well as Audit Committee	18/18	6/6	5/5

• Defining the principles for the monitoring and evaluation of related party transactions
• Monitoring the sustainability reporting process
• Monitoring the identification of data reported in accordance with digital reporting and sustainability reporting regulation
• Monitoring the implementation of sustainability reporting verification

The Audit Committee convenes regularly, but at least twice a year. In 2025, the Audit Committee held six meetings. The attendance rate was 96%.

Human Resources and Remuneration Committee

The task of the Human Resources and Remuneration Committee is to prepare the remuneration and nomination matters of the CEO and other management of the company, as well as the remuneration systems for other personnel. The Human Resources and Remuneration Committee consists of the Chairman and two to three members, elected by the Board of Directors from among its members for one year at a time.

In 2025, the Chairman of the Human Resources and Remuneration Committee was Heikki Westerlund, and the members were Patricia Allam, Tapio Kolunsarka, and Tatu Vehmas.

The duties of the Human Resources and Remuneration Committee are:

• Preparing matters concerning the appointment of the CEO and other management and mapping their successors
• Preparing the remuneration and other financial benefits of the CEO and other management
• Preparing matters concerning the company's remuneration systems
• Evaluating the remuneration of the CEO and other management, and ensuring the appropriateness of the remuneration systems
• Evaluating and making recommendations to the Board of Directors on plans and other incentive schemes based on special rights entitling to shares

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ASPO
CORPORATE GOVERNANCE STATEMENT 2025

• Planning the remuneration of other personnel and organizational development
• Preparing the remuneration report
• Preparing the Board's diversity report
• Monitoring the need to update and compliance with the remuneration policy (with regard to the remuneration of the CEO)
• Answering questions about the remuneration report at the General Meeting
• Recommending, if necessary, an advisor to the company's Board of Directors and making a proposal for the remuneration of an expert

The Human Resources and Remuneration Committee convenes regularly, but at least three times a year. In 2025, the committee met five times, and the attendance rate was 95%.

Chairman of the Board

Since April 8, 2021, Heikki Westerlund (b.1966), M.Sc. (Econ.), has acted as the Chairman of the Board of Directors of Aspo Plc. Since April 6, 2022, Mikael Laine has acted as the Vice Chairman of the Board.

Diversity of the Board of Directors

Aspo regards diversity of the Board of Directors as a significant part of sustainable operations and a success factor that enables the company to reach its strategic goals. Diversity is part of an effective Board of Directors that is able to work together and respond to the requirements set by the company's businesses and strategic goals, and to challenge the company's executive management in a proactive and constructive manner.

The Shareholders' Nomination Board prepares and presents the proposal for the composition of the Board of Directors to the Annual General Meeting. When planning the composition of the Board of Directors, the Shareholders' Nomination Board takes into account these diversity principles and particularly the needs and development phases of the company's businesses, as well as the competence areas required by different Board committees. When selecting Board members, the key objective is to ensure that the Board of Directors as a whole supports the development of Aspo Plc's current and future business operations.

The Shareholders' Nomination Board defines and evaluates the competence, know-how, and suitability required of Board members so that each member can be assumed to have the required expertise and experience to carry out their duties successfully. The objective of the preparatory work of the Nomination Board is to ensure that the Board of Directors forms an effective entity.

Diversity of the Board of Directors is examined from different perspectives. For the composition of Aspo's Board of Directors, key factors are competence, with all board members supplementing each other, and education and experience in different markets and fields of business, and in management and operations in different development phases, as well as the personal characteristics of each member. In addition, diversity in the Board of Directors is supported by experience in an international operating environment and consideration of the age distribution, among other factors. The representation of women and men in the Board composition must be balanced.

The members of Aspo's Board of Directors must have the competence required for the position and the ability to allocate sufficient time to their duties. When composing the Board of Directors, long-term needs and succession planning are also taken into account. The composition of the Board of Directors and its number of members must enable the Board of Directors to work effectively.

Aspo's board members have expertise in all three ESG areas (environment, social responsibility and governance) both directly and indirectly through experts and training.

The Board evaluates and develops its expertise regularly through training, expert cooperation, and recruitment. This competence covers Aspo's essential topics (E1, S1, G1) and supports the management of key impacts, risks, and opportunities.

In 2025, diversity principles were estimated to have been achieved well. Three out of the seven Board Members were women, so 43% of the Board was composed of the under-represented gender. The Board Members' age range was wide; members represented age groups born between 1964 and 1994. The members had diverse relevant work experience and educational backgrounds, and have key experience in both domestic and international business operations.

CEO

Aspo Plc's CEO is appointed by the Board of Directors. The Board also approves the remuneration payable to the CEO, long-term and short-term incentive programs, and other terms and conditions of the CEO's service contract. The terms and conditions of the CEO's service are specified in writing in the CEO's service contract approved by the Board of Directors. The CEO is appointed for an indefinite term.

Rolf Jansson (b. 1969, gender: male), M.Sc. (Tech.), M.Sc. (Econ.), serves as the CEO of Aspo. The CEO leads and develops the Group's business operations and is responsible for the operational management in accordance with the guidelines provided by the Board of Directors. The CEO presents matters and reports to the Board of Directors. The CEO is responsible for the Group's administration in accordance with the instructions of the Board of Directors, for ensuring that the company's accounting complies with applicable legislation, and for the reliable management of the company's assets. The CEO also serves as the Chairman of the Board of Directors for subsidiaries, and as the operational supervisor for Aspo Plc's administration and for the Managing Directors of the sub-groups. Further

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ASPO
CORPORATE GOVERNANCE STATEMENT 2025

more, the CEO is responsible for the internal audit and for the Group's risk management, which are coordinated by the CFO.

GROUP EXECUTIVE COMMITTEE

The CEO is assisted by the Group Executive Committee. The Group Executive Committee is responsible for the implementation of Aspo Group's adopted strategy and its operations, and it prepares the Group's policies and common practices. The Group Executive Committee consists of the following members: the CEO; the CFO; Vice President, Corporate Development; Senior Vice President, Legal; and the Managing Directors of the Group's business units. The Group Executive Committee convenes at least six times a year.

REMUNERATION

The Remuneration Policy concerning Board members and the CEO was confirmed by the Annual General Meeting on April 4, 2023. The Remuneration Policy describes the decision-making procedures and principles concerning the remuneration of the Board of Directors and the CEO, and it is presented to the Annual General Meeting every four years or whenever amendments are made. The salaries, remuneration, and other financial benefits of the Board of Directors and the CEO are presented in a separate remuneration report, which is available on the company's website at www.aspo.com/en/governance/remuneration.

AUDIT

The statutory duty of the independent external auditor is, in particular, to ensure that the financial statements provide accurate and sufficient information about the company's financial results for the period and its financial position.

In accordance with the Articles of Association, the Annual General Meeting elects the auditor, which must be an auditing firm approved by the Finland Chamber of Commerce. In addition, the Annual General Meeting decides on the fee payable to the auditor and on the grounds for the fee. The term of the auditor ends upon the conclusion of the next Annual General Meeting following their election. When changing the auditor, the Annual General Meeting elects the new auditor based on the proposal of the Board of Directors, prepared by the Audit Committee.

The auditor selected by the Annual General Meeting is responsible for providing auditing guidelines and coordinating the auditing work throughout the Group. As part of the annual audit, the auditor audits the company's accounts and administration. In addition, the auditor audits the consolidated financial statements and other relations between Group companies. The auditor provides the company's shareholders with the auditor's report required by law in connection with the financial statements. The Board also receives other possible reports and statements issued by the auditor.

The 2025 Annual General Meeting elected the audit firm Deloitte Oy as the auditor. Jukka Vattulainen, KHT, KRT serves as the auditor-in-charge. In 2025, companies belonging to Deloitte Oy in Finland and abroad were paid around EUR 485,600 in fees for performing audits for Aspo Group and around EUR 380,000 for non-audit services.

SUSTAINABILITY ASSURANCE

The statutory duty of an independent external sustainability assurance provider is to assure the information presented in the sustainability statement.

According to the Articles of Association, the Annual General Meeting elects the sustainability assurance provider. The assurance provider shall be either an authorized sustainability auditor or an authorized sustainability audit firm. The Annual General Meeting also decides on the amount of remuneration to be paid to the assurance provider and the basis for its payment. The term of office of the sustainability assurance provider ends at the end of the Annual General Meeting following the election. When replacing the sustainability assurance provider, the Annual General Meeting elects the sustainability assurance provider based on a proposal by the Board of Directors prepared by the Audit Committee.

The Annual General Meeting 2025 elected Deloitte Oy as the Company's authorized sustainability audit firm, and Jukka Vattulainen, KHT, KRT as the auditor-in-charge. In 2025, companies belonging to Deloitte Oy in Finland and abroad were paid around EUR 72,000 in fees for assuring Aspo's sustainability statement.

INTERNAL CONTROL

The objective of Aspo's internal control is to ensure the profitability and efficiency of operations, reliable financial reporting, and compliance with the applicable laws and regulations and the agreed practices and operating principles. Aspo's internal control includes the control integrated into the business processes, the Group's management system, and financial reporting covering the entire Group. Internal control is an integral part of the company's management, risk management, and administration.

The aim of internal control is to create sufficient certainty of goals and objectives being reached in terms of the following:

• Operational profitability, efficiency, and capital management
• Reliability and integrity of financial and operational information
• Compliance with laws, regulations, and agreements, as well as ethical principles and social responsibility
• Safeguarding and responsible management of assets and brands

The responsibility to arrange internal control lies with the Board of Directors and the CEO, both at Group level and in the different businesses. The internal audit function sup

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ASPO
CORPORATE GOVERNANCE STATEMENT 2025

ports the Group and business management in their internal control responsibility, and the aim is to provide Aspo's Board of Directors with sufficient certainty of the effectiveness of internal control. The Audit Committee monitors the operations and effectiveness of the company's internal control at its meetings and reviews the plans and reports of internal control.

FINANCIAL REPORTING

The control of financial reporting is based on monitoring business processes. The information for financial reporting is created during the progress of business processes, and the responsibility for accurate information is shared by all participants in the process. The financial reporting process is decentralized, and it is monitored by the Audit Committee.

Consolidated financial statements are prepared in accordance with the IFRS standards, as adopted by the EU. The financial statements of the parent company and the Finnish subsidiaries are prepared in accordance with Finnish Accounting Standards. Each separate company complies with the legislation of the country in which the company is located, but reports the information in accordance with Aspo's internal accounting guidelines. Separate companies may have their own chart of accounts, but all information is consolidated based on a common chart of accounts at unit level, where its reliability is assessed before the information is transferred to Group level. Aspo Group's financial information is verified and assessed on a monthly basis. In each phase, the unit responsible for the quality and generation of information will assess its reliability. The Group-level monitoring and reconciliation mechanisms are used on a monthly basis.

The systems required for financial reporting are decentralized and used in accordance with the principles of internal control. The achievement of the set targets is monitored on a monthly basis within the Group's consolidation

and reporting system. In addition to actual and comparison figures, the system provides up-to-date forecasts. The reports are provided for Aspo's Board of Directors monthly. The Board of Directors assesses the Group's position and future based on the information provided.

In addition to the Audit Committee, the reliability of reporting and processes is assessed by an independent external audit firm.

INTERNAL AUDIT

Internal audit assists the Board of Directors in its control responsibility by, among other things, assessing the level of internal control maintained to achieve Aspo's operational targets. Internal audit supports the organization by assessing and verifying the effectiveness of business processes and risk management, as well as management and administration.

The operating principles for internal audit are approved as a part of the internal control principles provided by the Board of Directors. The Group's SVP, Legal and Sustainability, is responsible for the coordination of internal audit activities, and internal audit findings are reported to the CEO, the Audit Committee, and the Board of Directors. Internal audit is organized corresponding to the size of the Group. Additional resources and special expertise are acquired if necessary. Audits are based on risk assessment. The target of the assurance work and assessment includes the profitability and effectiveness of operations, the reliability of financial and operational reporting, compliance with laws, and the safeguarding of assets.

Written audit reports are prepared and distributed to the Group's CEO, the senior management of the audited business, and the management of the audited operation or unit. Internal audit prepares a summary report on conducted audits, the most significant findings, and agreed measures at least quarterly for the Audit Committee of Aspo's Board of Directors. The Audit Committee monitors

the operations and effectiveness of the company's internal audit at its meetings, and reviews the plans and reports of internal audit.

With the regulatory changes in sustainability reporting, Aspo will integrate sustainability reporting as part of its risk management and internal audit processes in the next few years.

RISK MANAGEMENT

The purpose of risk management is to promote the achievement of the Group's goals. Risk management

aims to proactively identify and manage potential problems and to identify and seize business opportunities. Risk management supports the development and implementation of Aspo's strategy.

The purpose of risk management is that:

• Aspo has an effective risk management control model, and related processes integrated into its business management.
• Managers have access to high-quality and up-to-date information about business risks and their control measures, providing support for decision-making.
• The probability of the materialization of risks and unexpected events and their impacts on financial performance and reputation can be reduced effectively.
• Risk management measures and selected control measures are based on Aspo's willingness to take risks and its ability to tolerate risks.
• Cooperation in risk management is effective between Aspo's different businesses.

The managers of the Group and its businesses are responsible for risk management. They are also responsible for determining sufficient measures and their implementation, and for monitoring and ensuring that the measures are implemented as part of the daily management of oper-

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ations. Risk management is coordinated by the CFO, who reports to the CEO.

The Audit Committee monitors the effectiveness of the risk management systems and deals with risk management processes, plans, and reports.

Each business has a separate risk management program. Business risks and their management are discussed regularly by the management teams of the businesses. The Group's shared functions ensure that sufficient risk assessment and reporting procedures are incorporated into the processes for which they are responsible. The Group's administration is responsible for Group-level insurance plans.

Characteristic risks in each business area are identified in the business units, assessed in the business units' management teams, and reported to the subsidiaries' Boards of Directors and, if necessary, also to Aspo's Board of Directors or the Audit Committee.

Risks are continuously assessed, and their management is discussed in the business units' management. Risk assessments are updated in accordance with Aspo's management policy, and the most noteworthy findings are presented in the quarterly interim reports.

Financial risks, their management principles, and the related organizations are presented in the notes to the financial statements.

RELATED PARTY TRANSACTIONS

Aspo complies with the legislation governing related party transactions, the Finnish Corporate Governance Code, and the rules and instructions of Nasdaq Helsinki Ltd. Based on these, Aspo must evaluate and monitor the business transactions in which it is engaged with its related parties and ensure that any conflicts of interest are appropriately addressed in decision-making. Aspo maintains a list of related parties and verifies any changes at least once a year. As a general rule, related party transactions that are essential for Aspo and that deviate from normal market conditions are prohibited. The Board evaluates related party transactions and may, at its discretion, approve a deviant related party transaction. In such a situation, the Company surveys the related party and implements a process in accordance with internal guidelines and applicable legislation to assess whether the transaction is appropriate. A related party transaction that is essential and deviates from usual business or market conditions is always reported along with implemented decision-making procedures in the financial statement. Aspo Plc's related party transactions are described in note 5.3 (“Related Parties and management compensation”) in the consolidated financial statements. Related party transactions were not significant for the company, nor do they differ from the company's normal business activities, and they have been carried out at normal market terms.

INSIDER ADMINISTRATION

Aspo Group complies with the EU's Market Abuse Regulation (EU No 596/2014) and regulations issued pursuant to it, and other applicable guidelines, including the insider guidelines of Nasdaq Helsinki Ltd.

Permanent insiders of Aspo Plc include the members of the Board of Directors, the Group Executive Committee, the auditor, and other individuals who have regular access to insider information. Individuals working in managerial positions at Aspo Plc include members of the Board of Directors and the Group Executive Committee. When necessary, Aspo establishes and maintains project-specific insider lists of persons involved in projects involving insider information.

A closed period of 30 calendar days before the publication of interim reports, half-year financial reports, and financial statements applies to individuals working in managerial positions at Aspo and to permanent insiders. During the closed period, these persons are prohibited from trading in Aspo's shares and other financial instruments on their own account or on the account of a third party. Furthermore, individuals entered in project-specific insider lists cannot trade in financial instruments or securities issued by the company during the specific project period. Individuals working in managerial positions at Aspo and their related parties must report any business transactions associated with the company's financial instruments to the company and to the Finnish Financial Supervisory Authority.

The Senior Vice President, Legal and Sustainability, is responsible for the control and monitoring of insider issues. Aspo Plc's insider register and project-specific insider lists are maintained in the Insider Elements service, which is an application service provided by Euroclear Finland for its customers to maintain registers associated with insider administration.

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ASPO
CORPORATE GOVERNANCE STATEMENT 2025

Board of Directors

DECEMBER 31, 2025

HEIKKI WESTERLUND

M.Sc. (Econ.) born in 1966

Gender: male
Board professional
Chairman of the Board since 2021
Member of the Board since 2020
Chairman of the Human Resources and Remuneration Committee since 2021
Member of the Audit Committee in 2020

Member of the Board, Duuri Group Oy, 2018-
Member of the Board, Marinetek Group Oy, 2021-
Member of the Board, Oras Invest Oy, 2022-
Chairman of the Board, Oriola Corporation, 2023-
Chairman of the Board, Kvanted Oy, 2023-

Independent of the company and its major shareholders.

Shareholding in Aspo Plc on December 31, 2025:
15,000 shares, 0.05% of share capital, held by related party company Heiwes Oy:
20,000 shares, 0.06% of share capital.

No holdings or rights based on share-based incentive plans.

MIKAEL LAINE

M.Sc. (Econ.) born in 1964

Gender: male
Member of the Board since 2016
Member of the Audit Committee since 2016

CEO, Royal Caribbean Group Finland, 2025-
Strategy Director, Cargotec Oyj, 2014-2025
Chairman of Board, Brandt Group Ltd Oy, 2025-
Vice chairman of Board, The Foundation for Business Students in Aalto University, 2025-

Independent of the company and its major shareholders.

Shareholding in Aspo Plc on December 31, 2025:
20,000 shares, 0.06% of share capital.

No holdings or rights based on share-based incentive plans.

PATRICIA ALLAM

M.Sc. (Econ.), MBA (IMD) born in 1985

Gender: female
Member of the Board since 2021
Member of the Human Resources and Remuneration Committee since 2024
Member of the Audit Committee 2021-2024

Senior Vice President, Finance and Investor Relations, Fastned B.V., 2023-

Independent of the company, dependent on its major shareholders.

Shareholding in Aspo Plc on December 31, 2025:
6,371 shares, 0.02% of share capital, held by related party company Havsudden Oy Ab:
3,412,941 shares, 10.86% of share capital.

No holdings or rights based on share-based incentive plans.

ANNIKA EKMAN

M.Sc. (Econ.) born in 1977

Gender: female
Member of the Board since 2024
Member of the Audit Committee as of 2024

Chief Investment Officer, Ilmarinen Mutual Pension Insurance Company, 2025-
Member of the Board, Cinia Oy
Member of the Nomination Committee, Orion Corporation
Member of the Investment Committee, Foundation for Economic Education, ITLA

Independent of the company and its major shareholders.

Shareholding in Aspo Plc on December 31, 2025:
no holdings.

No holdings or rights based on share-based incentive plans.

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ASPO

CORPORATE GOVERNANCE STATEMENT 2025

Board of Directors

DECEMBER 31, 2025

TAPIO KOLUNSARKA

M.Sc. (Eng.), M.Sc. (Econ.) born in 1975

KAARINA STÅHLBERG

Master of Laws, LL.M. born in 1966

TATU VEHMAS

Bachelor of Business Administration born in 1994

Gender: male

Member of the Board since 2022

Member of the Human Resources and Remuneration Committee since 2022

CEO, Insta Group Oy, 2023-

Member of the Board, Aidian Oy, 2023-

Member of the Board, Millog Oy, 2023-

Member of the Board, Senop Oy, 2023-

Independent of the company and its major shareholders.

Shareholding in Aspo Plc on December 31, 2025: no holdings.

No holdings or rights based on share-based incentive plans.

Gender: female

Member of the Board since 2023

Chairman of the Audit Committee since 2023

Executive Vice President, Legal Affairs and M&A, Posti Group Corporation, 2016-

Member of the Board and Chairman of the Audit Committee (2016-), Vaisala Corporation

Independent of the company and its major shareholders.

Shareholding in Aspo Plc on December 31, 2025: 4,000 shares, 0.01% of share capital.

No holdings or rights based on share-based incentive plans.

Gender: male

Member of the Board since 2018

Member of the Human Resources and Remuneration Committee since 2019

Member of the Audit Committee since 2020 and in 2018-2019

Chairman of the Board, SensorFu Oy, 2024-

Chairman of the Board, AEV Capital Holding Oy, 2020-

CEO, TAAVi Capital Oy, 2020-

Independent of the company, dependent on its major shareholders.

Shareholding in Aspo Plc on December 31, 2025: no holdings, held by related party AEV Capital Holding Oy: 3,296,344 shares, 10.49% of share capital.

No holdings or rights based on share-based incentive plans.

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ASPO
CORPORATE GOVERNANCE STATEMENT 2025

Group Executive Committee

DECEMBER 31, 2025

ROLF JANSSON

M.Sc. (Tech.), M.Sc. (Econ.) born 1969

Gender: male
CEO, Aspo Plc, 2021-

Shareholding in Aspo Plc on December 31, 2025: 100,000 shares, 0.32% of share capital.

ERKKA REPO

M.Sc. (Econ.) born 1970

Gender: male
CFO, Aspo Plc, 2024-

Shareholding in Aspo Plc on December 31, 2025: 19,106 shares, 0.06% of share capital.

TARU UOTILA

LL.M born 1970

Gender: female
Senior Vice President, Legal and Sustainability, Aspo Plc, 2022-

Shareholding in Aspo Plc on December 31, 2025: 3,000 shares, 0.01% of share capital.

KARRI KIVI

M.Sc. (Econ.) born 1974

Gender: male
Senior Vice President, Corporate Development, Aspo Plc, 2024-

Shareholding in Aspo Plc on December 31, 2025: 2,000 shares, 0.006% of share capital.

MATTI-MIKAEL KOSKINEN

M.Sc. (Econ.) born 1972

Gender: male
Managing Director, ESL Shipping Ltd, 2013-

Shareholding in Aspo Plc on December 31, 2025: 73,577 shares, 0.23% of share capital.

MISKA KUUSELA

M.Sc. (Tech.) and M.Sc. (Econ.) born 1969

Gender: male
Managing Director, Leipurin Oyj, 2023-

Shareholding in Aspo Plc on December 31, 2025: 3,000 shares, 0.01% of share capital.

MIKKO PASANEN

M.Sc. (Econ.) born 1973

Gender: male
Managing Director, Telko Ltd, 2019-

Shareholding in Aspo Plc on December 31, 2025: 61,000 shares, 0.19% of share capital.