Thank you, Chairman. Could you start with a brief outline of your educational and professional
history? M.D., Doctor in Medical Science (Ph.D) with a specialization in international health andtravel medicine. Work history in clinical trials until 2010 and after that in various roles in thevaccination program as a vaccine safety physician and as an effectiveness research physician. In thelast few years, I mostly researched influenza, coronavirus, RSV and pneumococcal disease. Who is
your employer? The Finnish Institute for Health and Welfare (THL). In addition to this expertise, do
you have any other positions of trust that you would like to mention here? For the past one and ahalf years I have been the chairwoman of SAGE, the World Health Organization's working group of
experts on vaccination. Three years before taking this role, I was chairwoman of SAGE's working
group on COVID-19. And that was also with the WHO? SAGE, yes. This lawsuit is related to theso-called COVID pass legislation, or certain sections of the Communicable Disease Act, which wasenacted in the fall of 2021. Have you been in any way involved in this legislative process, or has
your expertise been consulted on it? Yes, I have been consulted, and my role during COVID-19 was
to provide literature reviews together with other colleagues at the Ministry of Social Affairs and
Health (STM), and of course also for the use of THL itself. If you can answer in general terms, what
different sources did you personally / THL collect and draw this knowledge base from? Well, there
were several sources, so we exchanged information with colleagues from other countries, especiallyamong the Nordic countries, but also with other EU countries. The EU Health Security Committeeorganised, perhaps not weekly, but several meetings where we could hear the latest data frommanufacturers. And then, of course, from this WHO position, I was able to hear every week thelatest scientific findings from the various manufacturers before they reached the public. And ofcourse, then we followed up with publications that mostly came as preprints, meaning they were notpeer-reviewed. And we then made summaries of these for the use of the ministry and the THL. And
which was the ministry to which you provided this information? The Ministry of Social Affairs and
Health. (STM) Thank you. What was the COVID situation in Finland in autumn 2021? Let's talkabout September onwards, right up to the end of the year. How would you describe the COVID
situation? We were on a very upward curve. As the weather got colder, COVID-19 rates increased,laboratory-confirmed cases increased, and infections led to illnesses, hospitalizations, and deaths. It
was very much on an upward curve. From your point of view and that of the THL, how did you
understand the aim of the COVID pass legislation or the requirement of a COVID-19 certificate?
Why was such a law enacted? Well, it was to protect individuals and society. Individuals from
infection and disease, and society from over-extending hospital capacity. At the time it was started,
the understanding was that vaccination could prevent a significant amount of infections. The
situation then changed quite drastically during that autumn, and when we saw the new variants
coming, especially the Omicron variant that came after the Delta, the parameters that were used as abasis for this legislation in late summer and early autumn were no longer valid in the same way.
Were you personally in favour and did THL as an organisation advocate for the introduction of this
COVID pass, i.e. the application of this COVID pass legislation? Yes, the first statements we madewere in favour. It was well known that there were not enough intensive care beds in Finland, and if
the epidemic had started to accelerate in the autumn in the same way as in China and Italy in early
2020, for example, we would have had quite a catastrophic situation. And therefore it was thoughtthat by restricting people's access to public events (which were seen as transmission-friendly
environments) with this COVID pass, so that whether the person was vaccinated or showed no
detectable COVID from his respiratory tract within a certain number of hours, the pass would thenprotect both individuals and society. That was the starting point. And it was not only Finland's idea,
but also that of the EU, and it also fulfilled the Commission's wish to work on this kind of nationalor even EU-wide standardised digital vaccination certificates. In this way, there were two purposes.
So, how did you assess the effectiveness of the COVID vaccines that were on the market in autumn
2021? And I would ask you separately to assess, if possible, in terms of preventing the infections
themselves or the infectiousness at a general level, and then in terms of preventing so-called serious
forms of the disease. And by serious forms of disease, I understand that you should refer to the needfor medical treatment, as it were, or at least that is what I mean by my question, so If you can saysomething about this. When we started working on the COVID pass, at the end of summer 2021, we
had information about the original Wuhan virus, Alpha and Beta and also Delta, and how well theinfection caused by them was preventable. It didn't prevent infections nearly as well as it prevented
severe disease. The prevention of infection was perhaps in the order of 50 %, and for severe diseaseeven over 90 % at that time in the early stages. This protective effect against infection fell quite
quickly, we were talking about some months, and that at six months it was already at zero, whenthese initial variants or Alpha, Beta and Delta were in circulation. In contrast, at that time theprotective effect against severe disease remained for many months and the decline rate was verysmall, just a few percentage points. Then in October we got the first data from South Africa on the
Omicron variant. And the information was then of course shared informally, and the first research
reports on Omicron and the effect of vaccines on its transmission or the disease caused by it were
published in late November. And of these, in fact, we then made our first science report on
December 10th. And then it was quite clearly seen that the protective effect both for severe disease,and then for transmission in particular, had come down 20-30 percentage points. And also its
protective power fell even faster, we were talking about two or three months, when it went from areasonable 40 percent down to zero. So clearly this situation had changed. The virus had been able
to develop a form of itself that evaded that antibody protection with the result that even thevaccinated were shedding the virus and might even be shedding as much as the unvaccinated. So
the basis for this COVID pass, in the form it was, clearly weakened towards the end of the year.
And in fact, at the end of the year, then, when the STM asked again from the THL what our current
thinking was about extending the validity of the COVID pass, we then stated, at the turn of the year,that the conditions from six months earlier were no longer met. Right. Do you have any information
as to whether the COVID pass was extended after the turn of the year or did they follow yourrecommendation and discontinue it? As I recall, it was valid until June 2022 officially, but how
much it was used for different events or restaurants, I don't have a very clear idea. I guess you'dhave to ask them separately how much of it was implemented. This discussion took place in early
2022, when we made our statement and expressed our view. We have a couple of exhibits on therecord here. We have them under evidence numbers V2A and 2B. There is this COVID informationfrom STM and THL, but before I present it or ask you about it, I will ask you a question without
those documents. You told us that the Omicron variant had been detected and it was making its
appearance in late autumn 2021. Was, however, the so-called mainstream virus, still the Delta
variant at that time in November-December 2021? So yes, in Finland the first Omicron occurrenceswere confirmed in December, if I remember correctly. It should be checked now when they came.
The situation doesn't immediately change, it is not black and white. One variant comes down andthe other goes up. We were in a dynamic phase. Yes. Do you remember exactly, and if you don't
remember we can look at the evidence, but do you remember in December 2021 what therelationship was between these variants? Out of the confirmed cases of infection, what part was
Delta and what was Omicron? I don't remember those ratios, I do not have the curve here. It isbetter if we look it up from there. And of course, we have to take them with the caveat that it
depends on how many samples are taken. And that's why we set up this wastewater monitoring, sothat we can better see these relationships at the population level. The test samples are influenced by
the fact that especially in the beginning they might have been targeted more at very sick people andless at not-so-sick people. So there can be this kind of bias from that point of view. Yes. Well, let'slook at that first evidence, the V2A. We have it on here now, was it number three? At least it doesn'tshow here. Right, it's not on any screens yet, it just takes a while. If you, Iiris, first show the first
page, Hanna Nohynek will see from which document this has been taken. So this is the type of
document we have here as evidence, the STM and THL status report on the COVID-19 situation.
And then if you go to the page that was just shown. Here is a statement, and this was dated 9
December 2021, that nine Omicron cases have been identified. First of all, I would ask, since this
now appears to be a joint document of the THL and STM, as well as the otherequivalent to be looked at in a moment, were you involved in the preparation of such info
documentation, or were you aware that these status reports were prepared? Yes, we prepared thesetogether, so this was prepared by our virologists, they did these variant analyses weekly, as in fact
they still do, though less frequently. From this, you can clearly see that the Delta has been the
predominant virus up to week 45-46. What happened since then is that Delta gradually decreased
and Omicron gained a foothold. But as you can see from these, there are other variants out there.
And in this situation, nine cases had been observed and several cases were under investigation. It
takes a little longer than a week to obtain the sequence data. So these are always then completed
afterward. Yes. So, Omicron is also referred to in the next evidence V2B. And here the date of thisdocument seems to have been 21 December 2021. So here we have 83 confirmed cases, andapparently this information has come from your laboratories? It comes from our laboratories. Our
virologist does these sequence analyses and we see them weekly in our meetings. During that time I
think we held COVID status update meetings every other day. And during those, we then jointly
compiled these slides for STM and THL media briefings. In this same slide, there is in that last balla statement that the vaccine protection against severe disease is still very good and after the third
dose almost as good as against previous forms. Was this still the THL's view back in December
2021? Yes, so this was precisely the fact that the bad news was that Omicron had come and it soquickly seemed to take over. It was very fast-spreading. But then when we looked at the protectionof the vaccine specifically against disease leading to serious cases of hospitalization, then although
we had a vaccine that coded the original virus, it also protected against Omicron. That was really
good data, and this data did not come from our own data, it came from the South African and thenalso from the UK data. They were very quick at getting it from around the world. It took us a bit
longer to produce our own reports. We don't need to look at these pieces of evidence any further. We
presented them yesterday to the court as written evidence. These were just a couple of things I
wanted to go over with you. You talk about the vaccination passport in that expert report that werequested. What do you mean by that? I understand that you saw it as some kind of, and it can beread in your testimony as perhaps some kind of better alternative to the COVID pass at some point.
What do you mean by that? Well, the idea of the COVID pass was that we would stop the spread of
the virus and thereby reduce the burden of disease in society. You could get it with two doses ofvaccine, three doses of vaccine or a negative test result. As I recall, within 75 hours. It has to bechecked. Then when Omicron came along and when more information came out that even thevaccinated can excrete the virus and in such a way that you can transmit it to someone else, then it
became clear without a doubt that people like this, who think they can come to an event with the
COVID pass and stay healthy, well they don't get that protection anymore. So they are in this kindof event, a public event, at high risk of getting the Omicron variant from a vaccinated person. And
that is why it seemed misleading to talk about a COVID pass protecting you somehow, whenunvaccinated people in that situation would be just as vulnerable regardless of whether the personnext to them were vaccinated or unvaccinated. Right. And how do you think this could have, maybe
it was already included in that answer but for the sake of clarity, how do you think this passportshould have or could have been changed, and in what way? Well, that depends entirely on what the
passport is used for. To this day, when I go to WHO headquarters in Geneva, I have to show that I
have the recommended vaccine doses, and I show them my COVID vaccination passport and I'mallowed in to lead the meeting. So this instrument is still being used, but there has to be a very clear
vision of what it is being used for. And what it was designed for in Finland, specifically to prevent
transmission and reduce the burden of disease, only part of it was justifiable. That is why the THL
then issued its statement at the turn of the year that when the majority of the population had thevaccinations required for the COVID pass and Omicron is the predominant virus, then the vaccines
in this situation do not effectively prevent the transmission of infections. What is your assessmentof the safety of these vaccines that were used in Finland as well as more broadly in the EU and theprocess by which they were selected for use? Well, these vaccines were studied in clinical trials inphase one and two and then they received marketing authorisation after they had been in phase threerandomised controlled trials, where it has to be granted that the follow-up period was not as long as
it normally is, but COVID was considered to be such a serious pandemic that this kind ofaccelerated marketing authorisation arrangement makes sense, that it saves lives. Subsequently,

after the marketing authorisation was granted, companies and public health institutions wererequired to carry out safety monitoring, and in these safety monitoring studies, various serious rareadverse events came to light, such as myocarditis caused by the RNA vaccine or very serious
thrombotic, thrombocytopenic syndrome caused by the adenovirus vector vaccine. On this basis,
public health institutions worldwide drew their own conclusions and limited the use of thesevaccines to groups where these risks were not considered so high. It is always a question of benefit
versus harm, and the benefit must greatly outweigh the harm. It is on that basis that the publichealth authorities make recommendations. The marketing authorisation holder naturally has to, or
the drug safety authorities will, restrict the marketing authorisation for a particular group. The
product information leaflet will include these researched findings and any restrictions. But if you
look at the big picture with the billions of doses of COVID vaccines that have been administered in
the world, when comparing benefit and harm, the benefit greatly outweighs the harm. As you arealso there in the WHO vaccine group, you are both a member and now also chairwoman, what is theWHO's view on whether and to what extent these COVID vaccines and other interventions haveachieved benefits? The WHO's view is that these vaccines saved millions of lives. The sad thing has
been that especially the lower-income countries did not get as many vaccines as they would havewanted and needed in the early stages of the epidemic. We thought that the mortality or morbidity
there would not be as high as in rich countries, but now with further analysis it has been found thatthe old population and those at risk there have also showcased high mortality and morbidity. Whatis your view and that of the THL's, regardless of whether they are the same or different, on thereliability of these COVID tests, namely the PCR tests, that have been used in Finland? PCR tests
are very sensitive and they are very specific too. The problem with them, of course, is that they canremain positive for a long time because they detect this kind of genetic material. It doesn't
necessarily tell the whole picture of infectivity. So a person can still excrete remnants of the virus
and no longer be infectious. It tells you that you have encountered the virus and become infected,
but the secretion can last for a long time. In contrast, antigen tests are not as sensitive nor as
specific. And of course, they have been used and are still being used. Just to check, when you
mentioned, going back a little bit, you mentioned that you go to that WHO office. So where is it
located, where are these meetings held? In Geneva. Yeah. You go there to Geneva, and what's theprocedure there that you have to pass to get to that meeting? You have to show an electronic
vaccination passport there. When you show your normal passport the guard will check whichcountry you are a citizen of and who you are, and then you show the electronic passport and only
then you can get in. Well, what would happen if you didn't have that passport? I actually don't know
if they would turn you back and you would have to get the recommended vaccinations. It hasn't
happened to me, my mobile phone has always worked and the e-passport has always been easily
visible from there. Well, do you know people like - and I'm not going to go any further here into the
topic brought up by the plaintiff, but this is the question I thought I'd ask. Do you know thefollowing people - Aseem Malhotra or Astrid Stuckelberger? I have heard the first name because theplaintiff has asked whether a conversation with the first person would be possible. With you? Yes.
And then the other name I don't remember hearing. Though emails can sometimes go to spam or beforgotten. Will the conversation that we asked for between you and Malhotra be arranged? Wehaven't set a date yet. Just a moment, Chairman. I'll check on something. That's all at this point,
thank you. Thank you, Chairman. I am the plaintiff's lawyer, Aki Nummelin. You mentioned that atsome point it became clear that a vaccinated person can also spread the virus to a vaccinated person
and then become ill. When did this become clear? I do not have that date here, but it can be found in
our scientific reports. The first weekly bulletin in which we reported on this Omicron variant to the
STM was on 10.12. So before that, of course, we had heard about this in these informal
consultations and networks, but that was the first time South Africa
had published based on a very small sample size of how Omicron evades the antibody protection
induced by either having had the disease or having received the vaccine. I would now like to show
the plaintiff's written exhibit number 13. The plaintiff's exhibit number 13, a medical study from
August 2021; they state in the summary that, among other things, the load of coronavirus measured

from a person who had received the full COVID vaccine series was similar to that of theunvaccinated and that the vaccinated also spread coronavirus. Are you familiar with the study? Yes,
so this has been known ever since the original vaccines came into transmission studies. They
weren't studied by the manufacturer for marketing approval, but we know that there isn't a 100 %protection against this infection and that there are very large individual differences in how much
virus an individual excretes. There are super-spreaders and then there are those who excrete very
little. And, as pointed out, it is entirely possible that a vaccinated person can shed as much virus asan unvaccinated person. It depends on the variant, it depends on the immunity of the person andother individual factors. This in itself is not new even in August, this was known before. Has thispossibly been known as early as the end of 2020? We should probably look at that from the workthat has been done and published. Not all of them may even have been published, and some of it
may be work done on just a few individuals. But before August 2021, this thing was known, thatvaccinated people also spread COVID. Yes. This was discussed among researchers, and this isactually typical of all respiratory viruses, so there is not really any vaccine that would prevent 100% of viral secretion. With bacteria, the situation is different. Perhaps a small detail. Is it the casethat once a person has received the COVID vaccine, it is only after 21 days that the person isrecorded as vaccinated? It depends on the analysis for which that information is needed. In theserandomized controlled trials, we talk about per-protocol analysis or intent-to-treat analysis. Per
protocol can be, for example, 14 days or 7 days. Intent-to-treat starts at the moment the person is
vaccinated. That's where the calculation of protection starts. Depending on what the data is needed
for, the analysis and the time that is needed can vary. What can the criteria be for determining where
this information is needed? Well, public health people need that intent-to-treat data because it
affects our disease burden. Vaccine efficacy starts slowly and ultimately peaks and then it comes
down from there. And everything that happens in between has an impact on the burden of disease.
But if we think about something, let's say the passport issue or for instance when it can be said thata person is sufficiently safe, then we need a longer time, because we know that the humanimmunological mechanism isn't on/off, but it starts to work little by little. Do you know whether the
COVID pass came into effect immediately after taking the COVID vaccines? We should check that
now to see if it was from that day, that vaccination day, and how it was among the different
countries and how it was with us. I don't have those details here, but it can be checked. Would you
have an educated guess as to how it was done in Finland? Well, from a biological point of view, I
would think that after the first dose, it can't be at the same moment, but it takes several days. And
after the second dose, immunologically speaking, the protective effect is achieved much more
quickly. We're talking about a few days. Let's assume that there is a situation in which anunvaccinated person enters a room, let's say a large room, with people who have taken the COVID
vaccines, and their passes are green, so to speak, is it possible that this unvaccinated person could
pose a danger to the vaccinated people in the room? Could you think of what the answer to this kindof a situation would have been in December 2021. Well, if in that room these vaccinated people arefragile, then the unvaccinated, of course, despite the vaccination, can be dangerous to them. And
this was precisely the reason why the THL recommended to the STM to create Section 48a of theCommunicable Diseases Act, so that health professionals would not be unvaccinated but would be
vaccinated and in that way would be less dangerous to these fragile already-vaccinated, because weknow that the protective effect is not 100 %. It's at best something like 90, but especially in older
people, it comes down quickly. Is it possible then to have a similar situation at the same time, inwhich a vaccinated person enters a room where there are a lot of vaccinated people. Is it possiblethat this vaccinated person entering the room could transmit the coronavirus, infecting the otherpeople already in the room? Yes. This was the problem with the COVID pass that the THL wanted
to highlight at the turn of the year, that the coronavirus passport as it was understood in the early
autumn of 2021, could create a false sense of security, because the vaccinated person may excrete
the virus. If the vaccinated person is very fragile, has a lot of underlying diseases and his responseto the vaccine is not very strong, then he is at risk. When did you first have access to thisinformation, the information that you have just given us? Well, we already had that information inearly autumn, based on this article, for example. But this is not an on-off thing, it is a question ofgradients. And if the gradient is more on the positive side, that it is useful, then that's why the THL
recommended implementing the COVID pass, and the purpose was explicitly to protect fragile
people and stop the circulation of the virus. But then when these reports started coming in fromSouth Africa in October and especially in November that despite vaccination, Omicron is evading
the antibody protection, then the question was raised as to how sensible this pass is. And then when
we received additional information, it led to the fact that at the turn of the year when STM asked
THL whether to extend the validity of the COVID passport, then we stated that the majority of the
population has the vaccinations required for the COVID pass, but with Omicron being thepredominant virus, the vaccinations do not effectively prevent the transmission of infection insituations where the COVID pass would be in use. But the risk of serious disease in thosevaccinated is very significantly reduced. This was our statement to the STM in that situation. But if
the information was already available in the summer of 2021, why was this not then passed on to
the STM, or was it? So in these literature reviews that we wrote, we did reference this information.
But as I said, it is not an on-off situation where all vaccinated would excrete a lot, but we knew that
there are super spreaders. And on average a vaccinated person back when there also was Alpha,Beta, and Delta around, so on average the vaccinated excreted less. You talked about fragile people
who are protected by the vaccine, so define a fragile person. You can either be fragile in terms ofage, we are talking about people over 80 or over 75, or you can have an underlying disease that
affects your immunity, i.e. you have cancer, you have cytostatic treatment, you have an immune
disease and you are taking biological drugs that affect your immunity. These are fragile people andthese are the people we particularly wanted to protect, because it was known that even getting
infected with a virus could lead to a path that would lead to death. No further questions. Chairman,
perhaps I missed the question in relation to the content of this statement. Would you confirm thecontents of this expert report that we have here in the court file, and I think you have it in front ofyou, dated August 30, 2023. Can you confirm that it was given by you, and you continue to be of
the same opinion as what is stated in that report. Yes, the facts that were available to us at the time,that is what I have recorded here. Even after this, I would like to return once more to the question of
the vaccination passport, as I am not quite sure that I understood it correctly. And now that I read it
here in the statement, and I think it is clearly stated here, I would like to ask once again whether
that's the way you saw it. That is, on the last page of the statement, which is the third page, you firststate in the first sentence of the top paragraph "THL also found that the unvaccinated could havebeen more efficiently protected by using a vaccine pass rather than a COVID pass." Then you go on
to talk about how the COVID passport could be obtained even with a negative test result, resulting
in an opportunity to get into an event restricted by the pass without having vaccine protection. Well,then you state there in the last paragraph, just before the signatures, "Therefore the THL consideredthat when using the COVID pass, it should only be issued based on vaccination status or contracted
disease." Am I now understanding correctly that, as such, the THL still considered in January 2022
that the COVID pass might be justified, but instead of being granted based on vaccination,
contracted disease, or a negative test result, if this third category dropped out then this would still be
ok? Yes. Then we can look at what the reasons are for using it, what the pros and cons are. And if I
compare again with the WHO situation, the WHO has taken the view that they are protecting
themselves and the people in the building by only allowing vaccinated people in. Thank you. That's
all I got, Chairman. Was there a request for a fee for today? Travel expenses only. And the amountis? Two times 2.95. Six euros. Is it to be paid by the state? Yes, we accept
this. That amount will be paid by the State alone. Yes.