The Listing and Surveillance Committee of Tallinn Stock Exchange reviewed the circumstances and materials collected in the course of supervisory proceedings carried out with respect to Arco Vara and decided to give a warning to AS Arco Vara for violation of TSE Rules chapter Requirements for Issuers (hereinafter RI) clause 4.3.2. and draw Arco Vara's attention to the necessity to evaluate its internal guidelines adequacy in accordance with the requirements of RI. Circumstances: 1. On May 21, 2008 and from July 21 to July 23, 2008, the spouse of a member of the board of AS Arco Vara Hillar-Peeter Luitsalu - Maie Luitsalu, bought 15 510 and 11 500 Arco Vara shares, respectively. 2. Arco Vara published its financial results for the 1st quarter of 2008 on May 29, 2008. Hence, according to the RI clause 4.5.2. the closed window period was from March 24 to May 29, 2008. 3. Arco Vara published its financial results for the 2nd quarter of 2008 on August 29, 2008. Hence, according to the RI clause 4.5.2. the closed window period was from June 23 to August 29, 2008. 4. TSE has sent Arco Vara two inquiries for clarifying the circumstances on August 27 and September 23, 2008, respectively. 5. In its answer from, Arco Vara explained that Maie Luitsalu was not aware of the closed window period of trading and bought the shares to own and not to speculate or to influence the market. Besides that, Maie Luitsalu assured that she did not possess any insider information that would have motivated her to make the transactions. 6. In its answer form September 25, 2008, Arco Vara declared that on May 21, 2008 at the time when Maie Luitsalu made the trades, there were three insider information cases about one of which Hillar-Peeter Luitsalu had information but relevant information was not in nature according to what it would have been possible to predict changes in the price of Arco Varra share or the influence on the share. In addition, Arco Vara confirms that during the council's meetings on April 14 and April 18, 2008 the interim report for the 1st quarter of 2008 was not ready and the financial results were not on the agenda. The next council's meeting was on August 25, 2008. 7. Neither the member of the council nor the person connected with him, Maie Luitsalu, had applied for the exception for trading during the closed window period to the exchange. Considering the materials submitted and the explanations given by Arco Vara, the Committee concluded that Arco Vara's activities have been in conflict with RI clause 4.3.2. Background: According to RI clause 4.5.2. are the persons connected with the members of he supervisory board not allowed to effect transactions in the Issuer's securities for their own account or through an intermediary during a period starting one (1) week before to the end of the reporting period and ending one day after the disclosure of the financial results of the Issuer for the reporting period (closed window). According to RI clause 4.1.1.1 is a person understood in possession of confidential information (insider) as a member of the supervisory board in addition to the legal acts. According to RI clause 4.2. are persons connected with insiders understood among others also the cohabitating spouse of the insider. According to RI clause 4.5.3. may the Listing Committee of the Exchange on the basis of a person's written application grant exceptions to the restriction set out in clause 4.5.2 of RI, if the Listing Committee believes that the transaction is not effected on the basis of inside information. According to RI clause 4.3.2. is an Issuer required to inform all the persons, who, pursuant to clause 4.1 of RI, are in possession of confidential information, of the provisions of these Requirements and to require such persons to act in accordance with these requirements. Tallinn Stock Exchange Market Services +372 6408800