Notification Οbligations

Regulation (EU) 596/2014 of the European Parliament and of the Council of April 16, 2014, on Market Abuse (Market Abuse Regulation – MAR), and Delegated Regulations 2016/522 and 2016/523 of the European Commission.

“Qualco Group S.A.” (the “Company”), aiming to inform its shareholders and the investing public about notification obligations and in compliance with relevant legislation for the protection of the capital market from acts by persons holding insider information and market manipulation, has adopted a process for reporting transactions of persons exercising managerial functions and their close associates (Required Persons) to the Company, alongside the transaction reporting process to the Hellenic Capital Market Commission, pursuant to article 19 of the MAR Regulation.

Persons exercising managerial duties, as well as those with close ties to them, must notify the Company and the Hellenic Capital Market Commission of every transaction carried out for their own account related to the Company’s shares or debt securities, or derivatives or other linked financial instruments, directly and no later than three business days after the transaction date.

Procedure and timing for submitting notifications – Relevant Authorities

Persons responsible for disclosure must inform about any changes in their holdings related to the voting rights of the issuer simultaneously to the issuer and the Hellenic Capital Market Commission, as soon as possible, and in any event within three (3) trading days after the date they:

• Become aware of acquiring or disposing of or the possibility to exercise voting rights, or
• should have become aware of such, considering the circumstances, regardless of the date of the transaction, or
• are informed of a fact referred to in paragraph 3 of Article 9 of Law 3556/2007.

To facilitate tracking trading days, the Hellenic Capital Market Commission publishes on its website (http://www.hcmc.gr) trading calendars of organized markets operating in Greece, per Decision 1/434/3.7.2007 of the Commission’s Board. When the above information is considered privileged, responsible persons must exercise due diligence in monitoring their trading orders, ensuring they are informed in a timely manner of execution or non-execution, and submit the necessary disclosures.

The disclosure includes:

• the percentage of voting rights held as a result of acquisition or disposal,
• the chain of controlled entities through which the voting rights are effectively held, if applicable,
• the date when the voting rights percentage reached, exceeded, or fell below the thresholds, and
• the identity of the shareholder, even if they are not entitled to exercise voting rights under Article 10, as well as the person authorized to exercise voting rights on their behalf.

Furthermore, it is noted that the notification form must be submitted to the issuer and the Hellenic Capital Market Commission, duly signed. A submission is considered legally signed if it bears the signature of the responsible person or another duly authorized person. In cases where the responsible person is a legal entity, the declaration must be signed by its legal representative. In any case, the relevant legal documents certifying authorization must be submitted along with the notification to the Hellenic Capital Market Commission, and they remain valid until revoked.

The simultaneous notification to both the issuer and the Commission is completed by submitting the relevant notification form, a template of which has been uploaded on the Hellenic Capital Market Commission’s website (http://www.hcmc.gr) in Greek and English. The template is accompanied by an annex, which must be filled out by the responsible persons with their personal details and submitted only to the Hellenic Capital Market Commission. When filling out the annex, it is recommended to include, in addition to the details specified, the patronymic (father’s name) of the responsible person.

It is important to note that the proper completion of the notification form is the responsibility of the responsible person, who is liable for any errors or omissions.

The legally signed notification form must be submitted:

To the issuer at the Company’s offices, located at 66 Kifisias Avenue, Marousi, Attica, 15125, to the Investor Relations & Shareholders Department (+30 210 6198903), during working days and hours, with the indication “Notification of significant changes in voting rights pursuant to Law 3556/2007.”

To facilitate shareholders, submission can also be made via email to ir@qualco.eu, accompanied by a cover letter including the sender’s details, signature, contact phone number, and the number of pages being sent. The responsible person must ensure successful sending and receipt of the documents by the competent Department of the Company, and  to the Hellenic Capital Market Commission, at the Commission’s central protocol office (3-5 Ippokratous Street, Postal Code 10679, Athens). The submission is addressed to the Directorate of Public Records and Supervision of Listed Companies of the Hellenic Capital Market Commission, Department of Supervision and Surveillance of Behavior of Listed Companies, with the indication “Notification of significant changes in voting rights pursuant to Law 3556/2007.”

Submission can also be made via fax: +30 210 3377243. In this case, the form must be accompanied by a cover sheet that includes the sender’s details, signature, contact phone number, and the number of pages sent. The responsible person must ensure successful transmission and receipt of the documents by the relevant protocol service.

In any case, the competent authority for supervising disclosure obligations is the Hellenic Capital Market Commission. The relevant notification form is available on their website  (http://www.hcmc.gr).