COMMITTEE'S DECISION ON AS SEB PANK


On April 20, 2009 the Listing and Surveillance Committee of NASDAQ OMX Tallinn
decided to give a warning to AS SEB PANK for violation of NASDAQ OMX Tallinn
rules and regulations chapter Requirements for Issuers (hereinafter RI) clauses
1.2.1., 5.4.2, 5.1.7, 5.4.5, 2.4.5, 2.4.8 and 2.4.1. 

Background:
According to RI clause 1.2.1 is the Issuer is obliged to secure disclosure of
information stated in RI in such a form and within such time limits as
specified in RI. 
According to RI clause 5.4.2, an Issuer of debt securities shall publish
semi-annual interim reports on its operations and financial results for 6
months and 12 months of the financial year (preliminary annual accounts),
consisting also data of relevant half-year. 
According to RI clause 5.4.5 is the Issuer obliged to make public an interim
report immediately after its preparation by the management board, but no later
than two months after the end of the reporting period. 
According to RI clause 5.1.7, at least the comments on the economic results,
the balance sheet and income statement shall be made public as a notice sent to
the Exchange. The full financial statements (the annual report and the interim
report) shall be sent to the Exchange in electronic form for publication on the
Website of the Exchange. 
According to RI clause 2.4.5, all notices and financial reports shall be made
public in Estonian and in English. 
According to RI clause 2.4.8, if possible, an Issuer shall make public all the
notices intended for disclosure in different languages simultaneously but not
later than on the following trading day. 
According to RI clause 5.1.3, the Issuer is obliged to make the balance sheet
and income statement public in the form of a comparative table comparing the
information to that of the same period of the previous financial year for
income statement and the previous audited financial year for balance sheet. 
According to RI clause 2.4.1 information is deemed disclosed when it is made
public as a notice through the Exchange Information System. 

On February 11, 2009, AS SEB Pank published a stock exchange announcement about
general indicators of its financial results for the year 2008. In addition to
the announcement, AS SEB Pank disclosed the full interim report in the Estonian
language on February 27, 2009. On March 20, 2009, AS SEB Pank published the
announcement about 12 months financial results and interim report that
corresponds with the stock exchange's requirements. On the same day AS SEB Pank
disclosed corrected full interim reports in Estonian and English on the
exchange's web-site. 


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