Nasdaq as a global business is committed to compliance with all applicable economic sanctions laws, including those of the European Union and the United States. Nasdaq notes the ongoing changes in sanctions related to Russia. For example, under US sanctions administered by the US Department of Treasury's Office of Foreign Assets Control ("OFAC"), it is prohibited for any United States citizen, lawful permanent resident, entity organized under the laws of the United States (including foreign branches), or any person in the United States (collectively, "US Persons") to engage in new investment in Russia as of April 6, 2022 under Executive Order 14071. Pursuant to OFAC guidance in its Frequently Asked Question ("FAQ") 1055, US Persons are not prohibited from purchasing equity in entities located outside of Russia, "provided that (i) such funds are not specifically intended for new projects or operations in the Russian Federation and (ii) the revenues of the entity located outside the Russian Federation are not predominantly derived from its investments in the Russian Federation". Nasdaq Helsinki Ltd reminds members that they are responsible for confirming their compliance with applicable sanctions restrictions, including conducting their own due diligence and other measures as appropriate. Members are responsible for confirming whether US sanctions would apply to their activities on the Nasdaq Helsinki Ltd operated markets and ensure that such activities are in compliance with applicable sanctions restrictions. Nasdaq Helsinki Ltd, Surveillance, survo@nasdaq.com, 358 9 6166 7260
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