Regulation on the Structure and Content of Financial Reports and Other Reports of a Pension Fund Management Company Managing Mandatory Pension Funds – Unofficial Consolidated Text (NN, Nos. 104/17, 118/21, 146/22 and 52/24)

Croatian Financial Services Supervisory Agency (HANFA), 10000 Zagreb, Franje Račkoga 6, P.O. Box 164, Croatia t: 01 6173 200, f: 01 4811 507, e: info@hanfa.hr, OIB (Tax ID): 49376181407, MB (Registration Number): 02016419, w: www.hanfa.hr

REGULATION ON THE STRUCTURE AND CONTENT OF FINANCIAL REPORTS AND OTHER REPORTS OF A PENSION FUND MANAGEMENT COMPANY MANAGING MANDATORY PENSION FUNDS (Narodne novine Nos. 104/17, 118/21, 146/22 and 52/24 – Unofficial Consolidated Text)

INTRODUCTORY PROVISIONS Article 1. This Regulation governs the accounting, content, format, publication, preparation and delivery deadlines for annual financial reports, financial reports for reporting periods during the business year by which the pension fund management company reports to HANFA and other external users on financial position, operational performance and cash flows, as well as other reports it prepares for HANFA's needs.

MAINTENANCE OF ACCOUNTING BOOKS AND PREPARATION OF FINANCIAL REPORTS AND OTHER REPORTS Article 2. (NN 52/24) (1) The pension fund management company is obliged to maintain accounting books, prepare accounting documents, value assets and liabilities, and prepare financial reports in accordance with the Mandatory Pension Funds Act (»Narodne novine« Nos. 19/14, 93/15, 64/18, 115/18, 58/20 and 156/23, hereinafter: the Act), regulations governing accounting, and International Financial Reporting Standards. (2) The pension fund management company is obliged to record business events in its accounting books using accounts at least within the scope of the account plan prescribed in Annex 1 of this Regulation.

CONTENT OF FINANCIAL REPORTS Article 3. (NN 52/24) (1) The financial reports of the pension fund management company consist of: – Statement of Financial Position, – Statement of Comprehensive Income, – Statement of Cash Flows, – Statement of Changes in Equity and – Notes to the Financial Reports.

(2) The pension fund management company is obliged to prepare annual financial reports for the business year with a balance as of 31 December, and financial reports for periods during the business year with balances as of 31 March, 30 June and 30 September of the current year. (3) Annual financial reports from paragraph 1 must be prepared in accordance with the structure and content defined on the forms Financial Reports of a Pension Fund Management Company, located in Annex 2 of this Regulation and audited by an independent authorized auditor. (4) Notes to the financial reports from paragraph 1 item 5 for periods during the business year should cover only significant business events and changes in accounting policies compared to the last published annual financial reports, as well as information on the guarantee fund (type of assets in which funds are invested and amount). (5) When preparing the Statement of Cash Flows from paragraph 1 item 3, the pension fund management company may use either the direct or indirect method. (6) In addition to reports from paragraph 1, HANFA may request additional data, information and explanations of certain items in the financial reports from pension fund management companies. (7) The pension fund management company is obliged to prepare and present the publication of receipts from Article 56 paragraphs 11 and 12 of the Act in the Notes to Annual Financial Reports from paragraph 1 item 5, structured in the form of a table in Annex 4. A pension fund management company managing only mandatory pension funds must structure the note as prescribed by point a) of Annex 4, and if it also manages voluntary pension funds, must structure the note as prescribed by point b) of Annex 4.

REPORT ON THE STRUCTURE OF FINANCIAL ASSETS AND LIABILITIES OF A PENSION FUND MANAGEMENT COMPANY Article 4. The pension fund management company is obliged, in addition to financial reports from Article 3, to prepare the Report on the Structure of Financial Assets and Liabilities of a Pension Fund Management Company from Annex 3.

DEADLINES AND METHOD OF DELIVERY Article 5. (1) Deadline for delivery of financial reports from Article 3 and reports from Article 4 for periods during the business year: – quarterly period with balance as of 31 March of current year is 30 April, – six-month period with balance as of 30 June is 31 July, – nine-month period with balance as of 30 September is 31 October.

(2) Deadline for delivery of audited annual financial reports and reports from Article 4 with balance as of 31 December is 30 April of the following year.

Article 6. (NN 52/24) (1) The pension fund management company delivers reports from Articles 3 and 4 to HANFA in electronic form in accordance with HANFA's technical instruction. (2) The pension fund management company is obliged to deliver reports from Article 3 paragraph 3, together with the authorized auditor's report on the audit of annual financial reports and the annual report, in the manner and in accordance with the Technical Instruction for using HANFA's data delivery service reports.hanfa.hr and the Instructions for filling out WEB forms for management companies: DZU UCITS, UAIF, OMD and DMD. (3) It is considered that the pension fund management company has delivered reports from paragraphs 1 and 2 at the moment when the report is accepted on HANFA's server for receiving reports. (4) In justified cases of technical inability to deliver or improperly delivered reports (e.g., system failure, inability to read received documentation, etc.) in the manner prescribed by paragraphs 1 and 2, the pension fund management company is obliged to deliver documentation in written form, directly or by post for timely reporting. The pension fund management company is obliged to deliver documentation in the manner prescribed by paragraphs 1 and 2 as soon as the reasons for such delivery cease, and no later than within 8 days from the cessation of circumstances causing technical inability. (5) In addition to reports from Articles 3 and 4, the pension fund management company is obliged to deliver upon HANFA's request other documentation or data for supervision purposes or for performing other tasks within HANFA's competence and scope regarding the pension fund management company's operations, in the manner prescribed by this Article and within the deadline specified in the request. (6) HANFA may, if necessary, request the pension fund management company to deliver certain documentation prescribed by this Regulation in original or certified copy, regardless of electronic delivery.

PUBLICATION OF FINANCIAL REPORTS Article 7. The pension fund management company is obliged to publish annual financial reports, as well as financial reports for periods during the business year, on its website, within deadlines equal to those for delivery in Article 5.

TRANSITIONAL AND FINAL PROVISIONS Article 8. This Regulation enters into force on the eighth day from the date of publication in »Narodne novine«, and is first applied to quarterly financial and additional reports with balance as of 31 March 2018.

Article 9. With the start of application of this Regulation, the Regulation on the Structure and Content of Financial Reports and Other Reports of a Pension Fund Management Company Managing Mandatory Pension Funds (»Narodne novine« Nos. 40/16 and 39/17) ceases to be valid.

TRANSITIONAL AND FINAL PROVISIONS Regulation on Amendments and Supplements to the Regulation on the Structure and Content of Financial Reports and Other Reports of a Pension Fund Management Company Managing Mandatory Pension Funds (Narodne novine 118/21), entered into force on 11 November 2021. Article 2. (1) This Regulation enters into force on the eighth day from the date of publication in »Narodne novine». (2) Forms from paragraph 1 are first applied to delivery of the report on financial assets and liabilities structure with balance as of 31 December 2021.

TRANSITIONAL AND FINAL PROVISIONS Regulation on Amendments to the Regulation on the Structure and Content of Financial Reports and Other Reports of a Pension Fund Management Company Managing Mandatory Pension Funds (Narodne novine 146/22), entered into force on 1 January 2023. Article 6. (1) This Regulation will be published in »Narodne novine« and enters into force on 1 January 2023. (2) The pension fund management company is obliged to deliver the first reports in accordance with Articles 4 and 5 for reporting periods starting from 1 January 2023. (3) Reports for periods until 1 January 2023 are delivered in accordance with Annexes 2 and 3 of the Regulation on the Structure and Content of Financial Reports and Other Reports of a Pension Fund Management Company Managing Mandatory Pension Funds (»Narodne novine« Nos. 104/2017 and 118/2021) in the manner prescribed by Article 2 paragraph 1 of this Regulation, which amends Article 6 paragraph 1 of that Regulation.

FINAL PROVISIONS Regulation on Amendments and Supplements to the Regulation on the Structure and Content of Financial Reports and Other Reports of a Pension Fund Management Company Managing Mandatory Pension Funds (Narodne novine 52/24), entered into force on 11 May 2024. Article 5. This Regulation enters into force on the eighth day from the date of publication in »Narodne novine».

ANNEX 1. ACCOUNT PLAN FOR A PENSION FUND MANAGEMENT COMPANY 0 INTANGIBLE, TANGIBLE ASSETS AND LONG-TERM INVESTMENTS 1 CASH AND RECEIVABLES 2 LIABILITIES 3 FINANCIAL ASSETS 4 SMALL INVENTORY 6 EXPENSES 7 REVENUE 8 OPERATING RESULT 9 EQUITY, RESERVES AND OFF-BALANCE SHEET RECORDS – 0 INTANGIBLE, TANGIBLE ASSETS AND LONG-TERM INVESTMENTS 00 Long-term intangible assets 01 Long-term tangible assets 02 Advance payments for acquisition of long-term tangible and intangible assets 05 Investments in affiliated companies 06 Investments in subsidiaries 08 Other assets 1 CASH AND RECEIVABLES 10 Cash and cash equivalents 10x Guarantee fund 11 Advance payments 12 Receivables from pension fund management 13 Interest receivables 14 Receivables from sale and purchase of financial instruments 15 Receivables from state units and other institutions 16 Receivables from employees 17 Other receivables 19 Prepaid future period expenses and uncollected revenue 19x Deferred tax assets 2 LIABILITIES 20 Liabilities from pension fund management 21 Financial liabilities 24 Payables to suppliers 25 Payables to employees 26 Liabilities for taxes, contributions and other fees 27 Liabilities for dividend or profit share payments 28 Provisions for liabilities 29 Deferred expense payment and future period revenue 29x Deferred tax liabilities 3 FINANCIAL ASSETS 30 Financial assets at fair value through profit or loss 30x Guarantee fund 31 Financial assets at fair value through other comprehensive income 31x Guarantee fund 32 Financial assets at amortized cost 32x Guarantee fund 4 SMALL INVENTORY 6 EXPENSES 60 Material costs 61 Service costs 62 Salaries, fees and similar remuneration costs 63 Other administrative expenses 64 Fund management expenses 640 Transaction costs 641 Costs for delegated management activities 642 Sales representative costs 643 Promotion costs 649 Other fund management expenses 65 Depreciation and value adjustments (excluding financial assets) 66 Losses from investments in financial instruments 660 Realized losses from sale of financial instruments 661 Unrealized losses on financial assets 662 Value adjustments for expected credit losses 669 Other losses from investments in financial instruments 67 Loss on sale of other assets 68 Interest expenses and negative exchange differences 680 Interest expenses 681 Negative exchange differences 69 Provision costs for unforeseen liabilities 7 REVENUE 70 Revenue from pension fund management fees 700 Entry fee 700x Entry fee for mandatory pension fund 700y Entry fee for voluntary pension fund 701 Management fee 701x Management fee for mandatory pension fund 701y Management fee for voluntary pension fund 702 Exit fee 702y Exit fee for mandatory pension fund 702y Exit fee for voluntary pension fund 71 Interest revenue 72 Positive exchange differences 73 Revenue from investments in financial instruments 730 Realized gains from sale of financial instruments 731 Unrealized gains on investments in financial instruments 732 Gains from value adjustments for expected credit losses 739 Other revenue from investments in financial instruments 75 Revenue from sale of other assets 76 Revenue from released provisions 77 Other revenue 79 Difference between revenue and expenses 8 OPERATING RESULT 80 Profit or loss before taxation 81 Income tax 82 Profit or loss after taxation 9 EQUITY, RESERVES AND OFF-BALANCE SHEET RECORDS 90 Paid-up and subscribed share capital 91 Reserves formed from profit after taxation 92 Capital reserves 93 Revaluation reserves 93x Revaluation reserves for financial assets and liabilities at fair value through other comprehensive income 93y Revaluation reserves for other assets 94 Other reserves 95 Retained profit, transferred loss, profit or loss of current year 950 Retained profit from previous periods 951 Transferred loss from previous periods 952 Profit of current year 953 Loss of current year 98 Active off-balance sheet records 99 Passive off-balance sheet records

ANNEX 2. FINANCIAL REPORTS OF A PENSION FUND MANAGEMENT COMPANY

Form IFP STATEMENT OF FINANCIAL POSITION Name of pension fund management company: ____________________________ Tax ID (OIB): ______________________________________________ As of date: _________________________________________ (in euros)

Account	Positions	AOP	31. 12. previous year	As of reporting date current period
31 + 31*	Cash and cash equivalents	2
30 + 31 + 13*	Financial assets at fair value	3
32 + 13*	Financial assets at amortized cost	4
12	Receivables from pension fund management	5
11 + 13 + 14 + 15 + 16 + 17	Other receivables	6
01	Real estate, plant and equipment	7
00	Intangible assets	8
19x	Deferred tax assets	9
02 + 05 + 06 + 08 + 19 (excl. 19x)	Other assets	10
	TOTAL ASSETS (∑ AOP1 to AOP10)	11
98	Off-balance sheet records	12
	EQUITY AND LIABILITIES	13
	Equity and reserves (∑ AOP15 to AOP20)	14
90	Share capital	15
91 + 92 + 94	Capital reserves	16
93x	Fair value reserves	17
93y	Other revaluation reserves	18
950 + 951	Retained profit or transferred loss	19
952 + 953	Profit or loss of current year	20
	Liabilities (Σ from AOP22 to AOP25)	21
20	Liabilities from pension fund management	22
21	Financial liabilities	23
24 + 25 + 26 + 27 + 28 + 29 (excl. 29x)	Other liabilities	24
29x	Deferred tax liabilities	25
	TOTAL EQUITY AND LIABILITIES (AOP14 + AOP21)	26
99	Off-balance sheet records	2