Name of the registers

Raisio plc’s shareholder register and records of Raisio plc’s general meetings

Controller and contact information

Raisio plc (Business ID 0664032-4)
Address: Raisio plc, P.O. Box 101 (Raisionkaari 55), FI-21201 RAISIO, Finland
Telephone: +358 2 443 2111

Queries about the shareholder register or the records of the general meetings can be addressed to Raisio plc’s Shareholder Services via e-mail osakaspalvelu(at)raisio.com or phone +358 (0) 2 443 2111 (weekdays from 9 a.m. to 3 p.m).

Queries about this privacy policy or data processing described herein can be made by contacting privacy(at)raisio.com.

Purpose and legal basis for processing personal data

The purpose of the processing of personal data is to maintain the shareholder register, as defined in the Finnish Companies Act (624/2006), and records of Raisio plc’s general meetings and to use the information contained therein for regulatory purposes.

The shares of Raisio plc are in the book-entry system maintained by Euroclear Finland Ltd (Central Securities Depository). The privacy statement of Euroclear Finland Ltd concerning the book-entry register can be found at www.euroclear.com/finland/en/who-we-are/gdpr.html.

The processing is also based on the company’s legitimate interests when, e.g. it is necessary to contact the shareholder or to provide information about a the general meeting.

The purpose for the processing of personal data in connection with general meeting is to enable the registration of shareholders, their representatives and their counsels to the general meeting, the identification of shareholders and their ownership and to enable the shareholders to exercise their rights, such as voting and presenting questions. In case the requested personal data is not provided, the Controller cannot accept the registration.

Categories of personal data and content of the register

The following personal data shall be recorded in the shareholder register:

• name
• name of the nominee registered shares’ account operator
• personal ID number or business ID
• contact, payment and taxation details
• number of shares by share class
• name of the central security depository in whose book-entry account the shares are registered
• historical information of the shares and information on dividends paid

For the purposes of general meetings, a shareholder register of shares belonging to a book-entry system on the record date of the general meeting and a list of shareholders, their assistants, and proxy representatives registered and participated in the general meeting are maintained.

The registers related to the general meeting contain the following personal data of the shareholder:

• name
• personal ID number or business ID
• contact information (address, telephone number, e-mail address)
• book-entry account number
• votes on agenda items
• name of any possible assistant
• name of any possible proxy and their ID number/date of birth

Information retention

The information in the shareholder register is kept as long as there has been no change in the shareholder information due to a change of ownership, after which the shareholder register is updated to reflect the current ownership.

Payment-related information is kept in the register in accordance with the Finnish Accounting Act and the Prepayment Act.

The information related to the general meeting will be kept in the register until the verification of those registered for the general meeting and the need for the data processing for the general meeting and the preparation of the minutes of the meeting have ended. The provisions of the Finnish Companies Act regarding the time limit for complaint require the company to keep personal data related to the general meeting for three months after the end of the general meeting. The list of participants, which includes the names, number of shares and votes of those who participated in the meeting, is attached to the minutes of the general meeting and is permanently stored as required by the Companies Act.

Under law, in the case of information pertaining to the book-entry register, including personal data, Euroclear Finland Ltd shall retain the data indefinitely as the controller of the book-entry register.

Sources of information

For the shareholder register personal data is recorded from the book-entry system.

Personal data for the records of general meetings is obtained from the shareholder register and from the shareholders themselves or the persons acting on their behalf or on their account.

Transfer or disclosure of personal data

Raisio plc may transfer or disclose personal data to third parties for the following purposes:

• to Euroclear Finland Oy Ltd, as the technical implementor of the registration and voting system for the general meeting and, when necessary, to other service providers acting for the Controller
• within the Group, and
• when disclosure is necessary in order to ensure the rights of the Controller, data subjects or others, to investigate potential wrongdoing or respond to authorities’ requests.

Under the rules of Euroclear Finland Ltd, the temporary shareholder register produced for a general meeting is public for the date of the meeting and its preceding three business days similarly to the actual shareholder register.

The following information on shareholders is available in the shareholder register: shareholder’s name and address or domicile, date of birth, nationality, ownership details and information on possible co-owners. A list of attendees to the general meeting may, in accordance with the Finnish Companies Act, be disclosed as a part of the general meeting material of Raisio plc.

The following information on the 100 shareholders with the largest quantity of shares are also disclosed on the Raisio plc’s website (www.raisio.com/en/investors/shareholders/shareholders/): name, quantity of shares, percentage of all shares, change in the number of shares and percentage in the past month, and number of votes. Raisio plc uses Eurolandcom AB as its technical service provider based on a written agreement between the parties.

Data may be processed also outside the EU and EEA using data transfer mechanisms approved by the Commission of the European Union, such as the standard contractual clauses. The processing of personal data in the book-entry system is carried out in third countries reported by Euroclear Finland Ltd, and Euroclear Finland Ltd is responsible for concluding the necessary agreements with its sub-processors.

The shareholder register is publicly available at the head office of Euroclear Finland Ltd. Euroclear Finland Ltd may disclose information to editorial or reseach purposes, as well as for direct marketing, unless the data subject has made a request to ban this kind of disclosure. Further information is available from Euroclear Finland Ltd at www.euroclear.com/finland/en/manage-your-securities.html#content_title_1817262997.

If a local register office has ordered that the disclosure of personal data of a shareholder be restricted under the Act on Population Information System and Certificate Services Provided by the Population Register Centre, and the company has been notified of said restriction, the municipality, address and other contact details recorded in the shareholder register for the shareholder in question may be disclosed only to authorities in the event that the conditions stated in the Act are met. The restriction on disclosure does not apply to a possible contact address listed in the shareholder register, which may be disclosed also to other parties than authorities.

Principles for the protection of personal data

Raisio plc applies appropriate physical, technical, and administrative protection measures to protect data from misuse.

Only those persons who have the right to process data for their work are entitled to use the systems where the personal data is kept. Each user has their own username and password. The information is collected in databases that are protected by firewalls, passwords and other technical measures. The databases and their backups, as well as physical documents are kept in locked rooms and only certain pre-designated persons can access the data.

Data subject’s rights

Data subjects may exercise their rights below in accordance with the applicable data protection legislation:

• Right of access – Data subjects have the right to access and review their personal data or verify that none of their personal data is stored in the records.
• Right to rectify inaccurate or incomplete data
• Right of erasure – if the data is no longer required for its specified purpose or there are no longer legal grounds for its processing. Personal data that must be processed to comply with statutory obligations may not be erased.
• Right to restrict processing, which means that means that the data will only be stored in the records until their accuracy has been verified.
• Right to object to processing for direct marketing purposes. Raisio plc does not process the data for direct marketing (however see above under ‘Transfer and disclosure of personal data’).
• As the processing of personal data is not based on consent or agreement, data subjects do not have the right to transfer their data to another controller.

Request shall be made in writing to the Controller to the address above. The data subject must prove his/her identity in an acceptable way.

If the request concerns information contained in the book-entry system Euroclear Finland Ltd must be contacted in order to make such a request.

The Data Subject is entitled to file a complaint with the supervisory authority if the Data Subject considers that personal data has not been processed in accordance with this Privacy policy or the law. In Finland: Office of the Data Protection Ombudsman, PL 800, 00521 Helsinki, Finland or e-mail at tietosuoja(at)om.fi.

Changes

Raisio reserves the right to change this Privacy Policy in order to develop its business operations or in case the legislation changes.

Updated on 8 February 2024