Insider Trading Rules

Based on the Dutch Financial Markets Supervision Act (Wet op het Financieel Toezicht; the “Wft”) and the EU Market Abuse Regulation, IMCD has adopted the IMCD Insider Trading Rules. The IMCD Insider Trading Rules apply to all IMCD employees and IMCD insiders including members of the Management Board and Supervisory Board. They contain rules on the possession of and transactions in IMCD and non-IMCD securities. The rules further contain in particular rules for persons, having access to inside information.