Instruction for Compiling the Monthly Statistical Report of an Investment Fund

---

INSTRUCTION FOR COMPILING THE MONTHLY STATISTICAL REPORT OF AN INVESTMENT FUND Zagreb, December 2025

TABLE OF CONTENTS 1 INTRODUCTION 2 REPORTING POPULATION AND INSTITUTIONS OBLIGED TO SUBMIT THE REPORT 3 REPORTING RULES 3.1 Reporting Frequency and Data Submission Deadlines 3.2 Type of Report 3.3 Format and Data Submission Channel 3.4 Reporting of Amounts 3.5 Level of Reporting 4 REPORTING REQUIREMENT 4.1 Concept of the Reporting Requirement 4.2 Header Description Feature 1. "Report Code" Feature 2. "Reporting Date" Feature 3. "OIB of the Investment Fund" Feature 4. "Name and Surname of Contact Person" Feature 5. "Contact Person's Phone Number" Feature 6. "Contact Person's E-mail Address" Feature 7. "Note" 4.3 Item Record Description 4.3.1 Features enabling identification of the item, instrument and its characteristics Feature 8. "Item Serial Number" Feature 9. "Instrument" Feature 10. "Currency" Feature 11. "ISIN" Feature 12. "Indexation Currency" Feature 13. "Original Maturity" Feature 14. "Relative Variable" 4.3.2 Features enabling identification of the counterparty Feature 15. "Country Code" Feature 16. "OIB of the Resident" Feature 17. "Non-resident Sector" 4.3.3 Feature enabling identification of the amount type Feature 18. "Amount Type" Feature 19. "Amount" 4.4 Reporting in case of merger, consolidation, division and termination 4.4.1 Consolidation (Spajanje) 4.4.2 Merger/Acquisition (Pripajanje) 4.4.3 Division (Podjela) 4.4.4 Termination (Prestanak) 4.5 Reporting rules in specific cases 4.5.1 Rules for reporting securities quantities in specific cases 4.5.2 Example of displaying discounted securities 4.5.3 Rules for reporting FX spot and forward transactions 5 INSTRUCTION FOR SUBMITTING THE MONTHLY STATISTICAL REPORT OF AN INVESTMENT FUND VIA TELECOMMUNICATIONS 5.1 Introduction 5.1.1 Standard file characteristics 5.1.2 File content 5.2 Record Content Control 5.2.1 Header 5.2.2 Items 5.2.3 Horizontal controls 5.2.4 List and detailed description of controls 5.2.4.1 Error list 5.2.4.2 Warning list 5.3 Correction of submitted data 5.3.1 Return file with processing status 5.3.2 Contact persons 6 DEVIATIONS IN REPORTING THE MONTHLY STATISTICAL REPORT OF AN ALTERNATIVE INVESTMENT FUND 7 LIST OF APPENDICES

INTRODUCTION

1. The Croatian National Bank (hereinafter: HNB) collects statistical data from investment funds in the Republic of Croatia through this reporting system. The collected data will be used by HNB to produce official statistics within its competence, such as: financial accounts, balance of payments, monetary and financial institutions' financial statistics and investment funds statistics, securities statistics and other statistics, as well as for reporting in accordance with the requirements of the European Central Bank (hereinafter: ECB), the Statistical Office of the European Union (EUROSTAT) and the Organisation for Economic Co-operation and Development (OECD).
2. Investment fund data will be collected via Hanfa's secure website.
3. The legal basis for collecting statistical data from investment funds includes: the Act on the Croatian Financial Services Supervisory Agency (Official Gazette, nos. 140/05, 154/11 and 12/12), the Act on Open Investment Funds with Public Offer (Official Gazette, nos. 44/16, 126/19, 110/21, 76/22 and 152/24), the Act on Alternative Investment Funds (Official Gazette, nos. 21/18, 126/19, 110/21, 83/23 and 152/24), the Regulation on the structure and content of annual and semi-annual reports and other reports of UCITS funds (Official Gazette, nos. 105/17, 98/20, 155/22 and 12/24) and the Regulation on the structure and content of annual and semi-annual reports and other reports of alternative investment funds (Official Gazette, nos. 155/22 and 12/24).
4. The obligation to collect, compile and submit statistical data to competent institutions of the European Union is prescribed by EU Regulation No. 2024/1988 concerning statistics on assets and liabilities of investment funds (ECB/2024/17), EU Regulation No. 2021/379 concerning the balance of monetary financial institutions sector in part relating to money market funds (ECB/2021/2), and ECB Guidelines (EU) 2024/2798 amending Guideline (EU) 2021/831 on statistical data to be submitted about financial intermediaries other than monetary financial institutions (ECB/2021/12) (ECB/2024/27).
5. Integral parts of this Instruction are: ▪ the file "IFON_2025.xlsx" containing appendices supporting the Instruction, and ▪ the corresponding XSD file which the Investment Fund Management Company (hereinafter: IFMC/DUIF) must adhere to when compiling the monthly statistical report.

REPORTING POPULATION AND INSTITUTIONS OBLIGED TO SUBMIT THE REPORT 6. The reporting population consists of all investment funds established in the Republic of Croatia under the Act on Open Investment Funds with Public Offer (Official Gazette, nos. 44/16, 126/19, 110/21, 76/22 and 152/24) and the Act on Alternative Investment Funds (Official Gazette, nos. 21/18, 126/19, 110/21, 83/23 and 152/24), which have operational approval from the Croatian Financial Services Supervisory Agency (hereinafter: Hanfa) or, in accordance with Hanfa's proposal for amending the establishment procedure of alternative funds, have a notification date from Hanfa regarding their establishment or are established by a special Act, provided that they were active for at least one day within the reporting period. 7. For the purposes of this reporting system, a newly established investment fund was considered active if it executed its first transaction, or issued at least one share/unit. 8. Institutions obliged to compile and submit the monthly statistical report of investment funds defined by this Instruction are Investment Fund Management Companies (IFMCs/DUIF) as legal representatives of the investment funds they manage, and closed AIFs with internal management (Art. 4, para. 5 of the Act on Alternative Investment Funds (Official Gazette, nos. 21/18, 126/19, 110/21, 83/23 and 152/24)).

REPORTING RULES Reporting Frequency and Data Submission Deadlines 9. The statistical report defined by this Instruction is submitted on a monthly basis. 10. The submission deadline for the monthly statistical report is prescribed depending on the type of investment fund's investments:

1. For money market investment funds, by the end of the 6th working day after the end of the reporting period (i.e., month),
2. For all other types of investment funds, by the end of the 18th working day after the end of the reporting period (i.e., month).
3. For the purposes of this Instruction, working days in a week are understood as Monday to Friday, excluding holidays.
4. The IFMC's reporting obligation for a specific investment fund is considered fully and properly fulfilled if, within the prescribed deadline, a report meeting all formal and logical controls described in Chapter 5 (technical part) of this Instruction is received on Hanfa's server.

Type of Report 13. The monthly statistical report provides unrevised data on an unconsolidated basis. The term "unrevised" refers to a report where data have not been revised by the authorized auditor of the reporting institution.

Format and Data Submission Channel 14. Data are submitted in the form of an XML file. The submission of reporting XML files is carried out via Hanfa's secure website, regardless of whether it is the initial submission or the submission of corrections. The website address and acceptance interface are defined by Hanfa.

Reporting of Amounts 15. Each item must contain an amount that, depending on the type of amount, refers to monetary value or quantity. 16. All amounts are expressed rounded to two decimal places. 17. The amount is generally presented as a positive value, unless the description of modalities explicitly states that the amount is presented with a negative sign. 18. The unit price associated with instrument I007 is exceptionally expressed in the original currency of issuance of the unit/share. 19. Amounts associated with all other instruments are expressed in euros and cents or as absolute numbers rounded to two decimal places. 20. The euro equivalent of amounts for all instruments denominated in foreign currency (except I007) is calculated by applying the average exchange rate of HNB, whereby:

• for converting balances, the average HNB exchange rate on the last day of the reporting period is used,
• for converting transactions and realized price adjustments, the average HNB exchange rate on the transaction date is used,
• for converting unrealized price adjustments, the average monthly HNB exchange rate in the reporting period is used,
• for converting write-offs (deletions), the average HNB exchange rate on the date of the decision to write off is used, or if that is not possible, the average monthly HNB exchange rate. The euro equivalent of amounts for all instruments denominated in foreign currency (except I007), which is not listed on the HNB exchange rate list, is converted to EUR by applying the HNB exchange rate list for other currencies that do not trade on the Croatian foreign exchange market.

21. The euro equivalent of amounts for all instruments (except I007) contracted with a currency clause is calculated by applying the agreed exchange rate.
22. For all debt securities not converted to EUR, the quantity is submitted in EUR by dividing the quantity in HRK (which is recorded in the SKDD registry) by the fixed conversion rate, rounded to two decimal places, in accordance with general rules for conversion and rounding under Art. 14 of the Act on the Introduction of the Euro as the Official Currency in Croatia (Official Gazette nos. 57/22, 88/22).
23. For all securities (debt and equity) for which the issuer has not performed conversion to EUR (in the SKDD registry and at the commercial court), Feature "Currency" in the monthly statistical report of an investment fund (IFON) must be reported with the currency code EUR.

Level of Reporting 24. For instruments Investments in debt securities (A003), Investments in shares (A012), Investments in investment funds (A014), Options (A004 and P003), Futures contracts – bills of exchange (A007 and P006), Warrants (A008 and P007), Issued units/shares of an investment fund (P001), and Securities received or given as collateral based on securities financing transactions (I001, I002, I003, I004, I005 and I006), reporting is performed at the ISIN level, i.e., at the counterparty level. 25. For instruments Unit Price (I007) and D002 – Fees paid by unitholders/shareholders to the IF from 1.1.20xx to 31.12.20xx, reporting is performed at the ISIN level. 26. For other instruments, the level of reporting is:

1. For resident natural persons collectively using a predefined OIB: 11111111111,
2. For resident self-employed persons collectively using a predefined OIB: 22222222222,
3. For other residents at the counterparty level, i.e., OIB, and
4. For non-residents collectively at the counterparty sector and country level.

REPORTING REQUIREMENT 27. Data collected via the monthly statistical report of an investment fund enables regular compilation and presentation of balances, transactions and other changes in financial instruments of the assets and liabilities of investment funds in the Republic of Croatia.

Concept of the Reporting Requirement 28. The reporting system is based on a report record consisting of a header record and item records. 29. The header consists of features that identify: the report code, reporting date and reporting unit (i.e., investment fund). 30. The items consist of features that identify: the item, instrument and its characteristics, counterparty description, amount type and amount. 31. A schematic representation of the report record for the monthly statistical report is shown in Appendix 1 of the IFON_2025.xlsx table. 32. The subject of reporting is an amount that needs to be uniquely described by:

1. features identifying the type of report and reporting date to which data relate,

2. a set of features identifying the reporting institution,

3. a set of features identifying the instrument,

4. a set of features identifying the counterparty,

5. a feature identifying the type of amount for which the amount is submitted.

6. Types of amounts for which data (amounts) are submitted in reporting records relate to:

7. balances on the reporting date, i.e., on the last day of the reporting month according to the investment fund's accounting policy, whether they are market values, fair values or other forms of bookkeeping balance recording. Balances are submitted separately for: a. principal – undepreciated/uncalled principal (amount type 01) and matured principal (amount type 16), and b. interest/dividend/profit share – undepreciated/uncalled interest/dividend (amount type 02) and matured interest/dividend (amount type 03),

8. transactions during the reporting month – transactions include increases and decreases and are presented, like balances, separately for: a. principal – increase (amount type 04) and decrease (amount type 05), b. interest/dividend/profit share – increase (amount type 19) and decrease (amount type 20),

9. price adjustments during the reporting month (amount type 06),

10. write-offs (deletions) during the reporting month are presented separately for: a. principal (amount type 17), b. interest/dividend/profit share (amount type 18),

11. quantities of securities, on the reporting date, i.e., on the last day of the reporting month (amount type 07), and

12. contracted values of financial derivatives representing off-balance sheet items (amount type 08).

13. The IFMC reports an item with an amount for each "Instrument" in the reporting month for which:

14. on the last day of the reporting month, it had a principal or interest/dividend/profit share balance greater than zero regardless of the amount type (matured or undepreciated), and/or

15. during the reporting period, it had a change in principal or interest/dividend balance relative to the previous reporting month due to an increase/decrease transaction, write-off or price adjustment. Instruments that do not meet the conditions stated under 1. and 2. are not reported in the reporting file. Footnote 1: Exceptionally, data for instrument D002 – Fees paid by unitholders/shareholders to the IF from 1.1.20xx to 31.12.20xx, may be submitted only on the reporting date 30.04 and relate to fees from 1.1. to 31.12 of the previous year.

16. The number of items reported by the IFMC via the XML file is variable for an investment fund across different reporting periods depending on investments and fund obligations in each individual reporting month. Similarly, the number of items varies from fund to fund within the same reporting month. Submission of items that are identical in all field values, except for the amount, is not allowed. Such items must be aggregated for submission purposes and reported as a single item.

Header Description 36. This part of the Instruction will detail features whose values must be entered to enable correct identification and classification of submitted data.

Feature 1. "Report Code" 37. This feature enables unique identification of the report. 38. The value of this feature for the monthly statistical report is "IFM02", which indicates: IF – investment fund as reporting unit, M – month as reporting frequency, while 02 indicates statistical unconsolidated unrevised report.

Feature 2. "Reporting Date" 39. This feature enables unique identification of the reporting date. 40. The date field is filled in the following format: "yyyy-mm-dd" and must refer to the last calendar day of the reporting month.

Feature 3. "OIB of Investment Fund" 41. This feature enables unique identification of the reporting institution, i.e., investment fund. This field contains the Personal Identification Number (hereinafter: OIB) assigned to the investment fund by the competent authority.

Feature 4. "Name and Surname of Contact Person" 42. This field serves to identify the contact person filling out the report of a specific investment fund. Only data for one contact person can be submitted in this field.

Feature 5. "Contact Person's Phone Number" 43. This field serves for up-to-date and accurate tracking of contact details of the person filling out the report. 44. The phone number with the area code of the IFMC person filling out the report is entered in this field.

Feature 6. "Contact Person's E-mail Address" 45. This field serves for up-to-date and accurate tracking of contact details of the person filling out the report. 46. The e-mail address of the IFMC person filling out the report or a generic e-mail address, for example back office of the IFMC, is entered in this field.

Feature 7. "Note" 47. Filling out this field is not mandatory and is used when the reporting institution wishes to clarify specifics relating to data in the file of a specific reporting month.

Item Record Description 48. This part of the Instruction describes a set of features enabling unique identification of the item, instrument and its characteristics, counterparty and amount type. 49. Reporting institutions must ensure tracking of the chronological sequence of data in preparatory databases so that distribution according to all item features is enabled in the monthly report items of an investment fund.

Features enabling identification of the item, instrument and its characteristics Feature 8. "Item Serial Number" 50. This feature enables unique identification of the item within the reporting file. 51. Each XML file item must contain a unique value of this feature in the same report, for the same reporting date.

Feature 9. "Instrument" 52. Each XML file item must contain the value of feature "Instrument" entered as one of the predefined instrument codes. Within a single reporting file, multiple items may contain the same value for feature "Instrument", provided that individual items differ in at least one field describing the instrument (e.g., counterparty or amount type). If items are identical in all fields except the amount, they must be summed for reporting purposes. 53. The value of feature "Instrument" is entered by selecting one of the predefined values, where the instrument code consists of four characters. The first character refers to an indicator representing whether the instrument is an asset (A), liability (P) or off-balance sheet item (I) and supplementary information (D). The remaining three characters refer to the instrument code. 54. If an item represents a balance/transaction of a financial instrument with an embedded derivative, where the derivative cannot be presented as a separate financial instrument, the value of the financial instrument is adjusted for the value of the embedded derivative and presented together with the corresponding instrument.

Asset Instruments Code Value | Name and Description of Instrument A001 | Transaction Accounts Instrument transaction accounts refers to funds on current or checking accounts opened with a resident or non-resident bank in domestic or foreign currency. Funds on current or checking accounts can be immediately converted into currency or are transferable by check, bank order, booking or similar means, without significant restrictions or penalties. A transaction account is an account opened with a bank based on an agreement to open such an account, for the purpose of paying its obligations and collecting receivables. This instrument can only be used to display funds in an account with a debit balance. A002 | Deposits Deposits, savings and time deposits refer to monetary funds of the reporting institution deposited with resident or non-resident banks, savings banks and housing savings associations, excluding transaction accounts. Unlike funds on current and checking accounts, deposit funds cannot be used for payments at any time. A share in a money market investment fund is not classified as a deposit but as instrument A014 – Investments in investment funds. A003 | Investments in debt securities Debt securities include all debt securities regardless of the contracted original maturity term and regardless of the contracted interest (discounted securities (e.g., treasury bills) or coupon-bearing securities (e.g., most bonds)). Debt securities do not give the investor a right to a share in the issuer's principal, but rather oblige the issuer to pay the investor a fixed amount of interest during an established period and return the borrowed amount in full upon maturity. Investments in debt securities also include ADRs (American Depositary Receipts) and GDRs (Global Depositary Receipts) issued based on debt securities. A004 | Options An option is a futures contract by which the buyer, by paying a certain compensation (commission or premium), acquires the right to sell or buy a specific financial instrument or commodity of the counterparty at an established price on a specified date in the future. For the seller of the option who received compensation, an obligation to buy or sell a financial instrument arises upon the initiative of the owner (buyer) of the option. A005 | Swap Contracts (Swaps) A swap contract is an agreement by which two parties have contracted the exchange of established values (cash flows) over a specified period. A006 | Futures Contracts – Forwards (Forwards) A forward is a futures contract relating to the deferred delivery of financial instruments or commodities. In such contracts, buyers and sellers commit to purchase or deliver, on a specified date in the future, a specific financial instrument or commodity at an established price or with a certain yield. Forwards are non-standardized futures contracts and are concluded on unofficial markets. A007 | Futures Contracts – Bills of Exchange (Futures) A bill of exchange (futures) is a futures contract relating to the deferred delivery of financial instruments or commodities. In such contracts, buyers and sellers commit to purchase or deliver, on a specified date in the future, a specific financial instrument or commodity at an established price or with a certain yield. Futures are standardized futures contracts traded on organized markets. A008 | Warrants (Warrants) A warrant is a security that gives the holder the right to buy shares at a pre-agreed price during the period until maturity, or on the maturity date of the warrant, and whose settlement is executed in cash or assets to which the warrant relates. A009 | Other Derivative Financial Instruments Representing Assets This instrument refers to other unmentioned derivative financial instruments. A010 | Lended Loans This instrument refers to monetary loans of an investment fund to another business entity. This instrument includes lended loans via the money market. A011 | Receivables based on securities financing transactions Receivables based on securities financing transactions include reverse repo credit transactions, securities borrowing transactions, buy/sell back transactions and similar. A reverse repo credit is a loan agreement in which the lender simultaneously agrees to purchase certain assets (e.g., securities) and sell them, at a pre-agreed price, on call, after a certain period or in the event of certain unforeseen circumstances. A securities lending transaction is an agreement under which the recipient temporarily takes over securities from the lender with the obligation to return them, upon expiration of the term or on call. A buy/sell back transaction is an agreement under which one party purchases certain assets (e.g., securities) from another contracting party.