Regulation on Annual, Semi-Annual and Other Reports of the Voluntary Pension Fund – Unofficial Consolidated Text (NN, No. 104/17, 98/20, 146/22 and 62/24)

Croatian Financial Services Agency, 10000 Zagreb, Franje Račkoga 6, P.O. Box 164, Croatia t: 01 6173 200, f: 01 4811 507, e: info@hanfa.hr, OIB: 49376181407, MB: 02016419, w: www.hanfa.hr REGULATION ON ANNUAL, SEMI-ANNUAL AND OTHER REPORTS OF THE VOLUNTARY PENSION FUND (NN 104/17, 98/20, 146/22 and 62/24 – Unofficial Consolidated Text)

INTRODUCTORY PROVISIONS Article 1. (NN 62/24) This Regulation governs the accounting, content, structure, publication, method and deadlines for preparation and submission of annual and semi-annual reports for reporting periods during the financial year, which pension companies report to the Croatian Financial Services Agency (hereinafter: Hanfa) and other external users regarding the financial position, operational performance and cash flows of the voluntary pension fund (hereinafter: fund), the fund's chart of accounts, and other reports prepared by the pension company for Hanfa's purposes.

MAINTENANCE OF BUSINESS BOOKS AND PREPARATION OF ANNUAL AND SEMI-ANNUAL REPORTS Article 2. (NN 62/24) (1) The pension company is obliged to maintain business books for the fund it manages, prepare accounting documents, value assets and liabilities, and prepare annual and semi-annual reports in accordance with the Act on Voluntary Pension Funds (»Narodne novine« 19/14, 29/18, 115/18 and 156/23; hereinafter: Act), regulations governing accounting, and International Financial Reporting Standards. (2) The pension company is obliged to record business events in the fund's business books using accounts at least within the scope of the chart of accounts prescribed in Appendix 1 of this Regulation.

CONTENT AND FORM OF ANNUAL AND SEMI-ANNUAL REPORTS Article 3. (1) The fund's annual and semi-annual reports consist of: – Statement of Financial Position, – Statement of Comprehensive Income, – Statement of Cash Flows, – Statement of Changes in Net Assets of the Fund, – Statement of Key Indicators of the Fund, – Statement on Valuation of Assets and Liabilities of the Fund, – Notes to Financial Statements. (2) The pension company is obliged to prepare annual reports for the fund it manages for the financial year period with a balance as of the last day of the fund's financial year, and semi-annual reports for the first six months of the financial year with a balance as of the last day of the semi-annual period. (3) The pension company is obliged to prepare semi-annual and annual reports for the fund it manages in accordance with the structure and content defined by the Annual and Semi-Annual Fund Reports forms in Appendix 2 of this Regulation. (4) Annual reports from paragraph 1 of this Article must be audited by an external independent licensed auditor, and prepared in accordance with the structure and content defined by the Annual and Semi-Annual Fund Reports forms in Appendix 2 of this Regulation. (5) Notes to the reports from paragraph 1, item 7 of this Article for periods during the financial year should cover only significant business events and changes in accounting policies compared to the last published annual reports. (6) In the notes to the annual reports from paragraph 1, item 7 of this Article, the pension company is obliged to disclose each individual investment:

1. in transferable securities and money market instruments issued by related parties of the pension company
2. in shares of investment funds managed by a related party of the pension company
3. impact of investments from points 1 and 2 of this paragraph on profit or loss and the fund's financial position (7) The pension company is obliged to disclose in the notes to the annual reports from paragraph 1, item 7 of this Article, a summary of fees and other transaction costs incurred during the purchase or sale of financial instruments mediated by the fund's related party. (8) When preparing the Statement of Cash Flows from paragraph 1, item 3 of this Article for the fund it manages, the pension company may use either the direct or indirect method. (9) In addition to the reports from paragraph 1 of this Article, the Agency may request additional data, information and explanations for certain items in the fund's financial statements from pension companies. (10) The pension company is obliged to additionally describe in the fund's annual report, besides information prescribed by the Accounting Act: – significant economic and macroeconomic trends during the reporting period, which directly or indirectly affected the fund's operations, or their impact on the movement of the fund's net asset value and individual asset classes, including the fund's exposure to significant risks, – measures and activities undertaken to implement investment policy and make investment decisions in relation to market, economic and macroeconomic trends, as well as activities undertaken to manage exposure to significant risks. – achieved effects and results of the applied measures and activities from the previous item.

OTHER REPORTS OF THE FUND Article 4. (NN 62/24) (1) Other fund reports in addition to annual and semi-annual reports are: – report on realized profits (losses) of the fund, – report on unrealized profits (losses) of the fund, – report on additional information about the fund, – statistical reports, – Deleted. (2) The pension company is obliged to prepare for the fund it manages reports from paragraph 1, items 1 and 2 of this Article, for semi-annual and annual periods, on forms whose structure and content are prescribed in Appendices 3 and 4 of this Regulation. (3) The report on additional information about the fund from paragraph 1, item 3 of this Article consists of three forms: – Number of members, amount of contributions to personal accounts and payments upon termination of membership in the fund (Form DI-DMF-1), – Gender and age structure of fund members (Form DI-DMF-2) and – Claims of the fund from the Ministry of Finance and payments of state incentive funds to members' personal accounts (Form DI-DMF-3), which the pension company is obliged to prepare in accordance with the structure and content defined in Appendix 5 of this Regulation. (4) Statistical reports from paragraph 1, item 4 of this Article are fund operation reports whose content, form and submission deadlines, depending on the needs of research/analysis of the non-banking financial services system, public reporting and service users, and exchange of information with other supervisory authorities and/or institutions responsible for statistics, are created by the Agency. (5) Exceptionally from paragraph 4 of this Article, without affecting the principles of competence, confidentiality and data protection, the Agency may accept statistical questionnaires or methods of data collection created by other supervisory authorities and/or institutions responsible for statistics. (6) The pension company is obliged to prepare and submit reports from paragraph 5 of this Article in the manner and within deadlines according to the Agency's request. (7) Deleted.

DEADLINES AND METHOD OF SUBMISSION Article 5. (1) Semi-annual fund reports prepared for the first six months of the financial year are submitted to the Agency within two months from the end of the first six months of the financial year. (2) Audited annual reports prepared for the financial year are submitted to the Agency within four months from the end of the financial year.

Article 6. (NN 62/24) (1) The pension company is obliged to prepare for the fund it manages reports from Article 4, paragraph 1, items 1 and 2 of this Regulation within deadlines identical to those in Article 5, paragraph 1 and 2 of this Regulation. (2) The pension company is obliged to prepare for the fund it manages the report from Article 4, paragraph 1, item 3 of this Regulation, i.e., forms from Article 4, paragraph 3 of this Regulation, within the following deadlines: – Form DI-DMF-1 for each month of the year, within 8 days from the last day of the month, – Form DI-DMF-2 for the first three months of the calendar year, for the first six months of the calendar year, for the first nine months of the calendar year and for the entire calendar year within one month from the end of the reporting period, and – Form DI-DMF-3 for the calendar year in which claims based on state incentive funds (hereinafter: SIP) arose, within a deadline identical to that in Article 5, paragraph 2 of this Regulation. (3) Deleted.

Article 7. (NN 62/24) (1) The pension company is obliged to submit to Hanfa reports from Article 3, paragraphs 2 and 4, and Article 4, paragraph 1, items 1, 2 and 3 of this Regulation in accordance with the Technical Instruction for using the electronic data submission system of the Croatian Financial Services Agency (reports.hanfa.hr). (2) The pension company is obliged to submit for the fund it manages annual reports from Article 3, paragraph 4 of this Regulation, together with the auditor's report on the completed audit of annual reports and the fund's annual report, in the manner and in accordance with the Technical Instruction for using the electronic data submission system of the Croatian Financial Services Agency (reports.hanfa.hr) and the Instruction for filling out WEB forms for funds: UCITS, AIF, OMF and DMF. (3) It is considered that the pension company has submitted reports from paragraphs 1 and 2 of this Article at the moment when the report is accepted on Hanfa's server for receiving reports. (4) In justified cases of technical inability to submit or improperly executed submission (e.g., system failure, inability to read received documentation, etc.) in the manner prescribed by paragraphs 1 and 2 of this Article, the pension company is obliged to submit documentation in written form, directly or by post, for timely reporting. The pension company is obliged to submit documentation in the manner prescribed by paragraphs 1 and 2 of this Article as soon as the reasons for such submission cease, but no later than within 8 days from the cessation of circumstances causing the technical inability. (5) In addition to reports prescribed by Articles 3 and 4 of this Regulation, the pension company is obliged to submit upon Hanfa's request other documentation or data for supervision purposes or for performing other tasks within Hanfa's competence and scope regarding the fund's operations, in the manner prescribed by provisions of this Article and within the deadline specified in the request. (6) Hanfa may, if necessary, request from the pension company submission of certain documentation prescribed by this Regulation in original or certified copy, regardless of electronic submission. (7) The pension company is obliged to act in accordance with Article 198, paragraph 3 of the Act within 15 days from receipt of the request.

PUBLICATION OF ANNUAL AND SEMI-ANNUAL REPORTS Article 8. (1) The pension company is obliged to publish audited annual and semi-annual reports of the open fund it manages on its website within deadlines identical to those in Article 5 of this Regulation. (2) The pension company is obliged to have reports from paragraph 1 of this Article published on its website for at least the last 5 financial years or from the beginning of the open fund's establishment if the fund operates for less than 5 years.

TRANSITIONAL AND FINAL PROVISIONS Article 9. This Regulation enters into force on the eighth day from the date of publication in »Narodne novine«, and is first applied to semi-annual reports and other reports with a balance as of June 30, 2018.

Article 10. With the start of application of this Regulation, the Regulation on Annual, Semi-Annual and Other Reports of the Voluntary Pension Fund (»Narodne novine« No. 40/16 and 41/17) ceases to be valid.

TRANSITIONAL AND FINAL PROVISIONS Regulation on Amendments and Supplements to the Regulation on Annual, Semi-Annual and Other Reports of the Voluntary Pension Fund (Narodne novine No. 98/20), entered into force on September 10, 2020. Article 8. (1) This Regulation enters into force on the eighth day from publication in »Narodne novine». (2) The first reporting date for the currency exposure report is November 16, 2020, and the first reporting period for the form Number of members, amount of contributions to personal accounts and payments upon termination of membership in the fund (Form DI-DMF-1) is October 2020.

TRANSITIONAL AND FINAL PROVISIONS Regulation on Amendments to the Regulation on Annual, Semi-Annual and Other Reports of the Voluntary Pension Fund (Narodne novine No. 146/22), entered into force on January 1, 2023. Article 9. (1) This Regulation will be published in »Narodne novine« and enters into force on January 1, 2023. (2) The pension company is obliged to submit the first reports in accordance with Articles 4 to 8 of this Regulation for reporting periods starting from January 1, 2023. (3) Reports for periods until January 1, 2023 are submitted on forms from the Appendix of the Regulation on Annual, Semi-Annual and Other Reports of the Voluntary Pension Fund (»Narodne novine« No. 114/2018 and 98/2020.) in the manner prescribed by Article 3 of this Regulation, which amends Article 7, paragraph 1 of that Regulation.

FINAL PROVISION Regulation on Amendments and Supplements to the Regulation on Annual, Semi-Annual and Other Reports of the Voluntary Pension Fund (Narodne novine No. 62/24), entered into force on May 30, 2024. Article 7. This Regulation enters into force on the eighth day from the date of publication in »Narodne novine».

APPENDIX 1. CHART OF ACCOUNTS OF THE FUND 1 Monetary funds and receivables 10 – Monetary funds 11 – Receivables from the sale of transferable securities and money market instruments 12 – Receivables from the sale of other financial instruments 13 – Receivables from dividends, monetary deposits and bond repayments 14 – Receivables from advanced payments granted 15 – Receivables from the pension company and depositary 16 – Receivables from share transfers 18 – Receivables from accrued interest and other assets 2 Fund liabilities 20 – Liabilities from investments in financial instruments 21 – Financial liabilities measured at fair value 22 – Financial liabilities measured at amortized cost 23 – Liabilities to the pension company 24 – Liabilities to the depositary 25 – Liabilities from permitted fund costs 26 – Liabilities from share transfers 27 – Liabilities for unissued shares 28 – Liabilities from accrued interest and other liabilities 3 Financial assets at fair value through profit or loss 30 – Debt transferable securities and valuation adjustments 31 – Money market instruments and valuation adjustments 32 – Equity transferable securities and valuation adjustments 33 – UCITS fund shares and corresponding funds and valuation adjustments 33x – UCITS fund shares and valuation adjustments 33y – Shares of open-ended investment funds with public offer from OECD member states similar to UCITS funds and valuation adjustments 34 – AIF shares and valuation adjustments 35 – Derivative financial instruments and valuation adjustments 37 – Investments in deposits and valuation adjustments 39 – Other financial instruments and valuation adjustments 4 Financial assets at fair value through other comprehensive income 40 – Debt transferable securities and valuation adjustments 41 – Equity transferable securities and valuation adjustments 49 – Other financial instruments and valuation adjustments 5 Financial assets at amortized cost 50 – Debt transferable securities and valuation adjustments 51 – Money market instruments and valuation adjustments 52 – Investments in deposits and valuation adjustments 55 – Other financial assets 6 Expenses 60 – Negative exchange differences 60x – Negative exchange differences of financial instruments at fair value through profit or loss 61 – Expenses from relations with the pension company 62 – Unrealized losses – adjustment to fair value 63 – Realized losses from sale of financial instruments 63x – Realized losses from sale of financial instruments measured at fair value 63y – Realized losses from sale of financial instruments measured at amortized cost 64 – Impairment of assets 64x – Losses from impairment for expected credit losses 64y – Impairment of other assets 65 – Depositary fee 66 – Transaction costs 67 – Interest expenses 68 – Other expenses from investments in financial instruments 69 – Other permitted fund costs 7 Revenues 70 – Interest revenues and amortization of premium (discount) 70x – Amortization of premium (discount) of assets with fixed maturity 70y – Interest revenues 71 – Positive exchange differences 71x – Positive exchange differences of financial instruments at fair value through profit or loss 72 – Unrealized gains – adjustment to fair value 73 – Realized gains from sale of financial instruments 73x – Realized gains from sale of financial instruments measured at fair value 73y – Realized gains from sale of financial instruments measured at amortized cost 74 – Dividend revenues 75 – Profit from reversal of impairment reserves for expected credit losses 76 – Other revenues 79 – Difference between revenues and expenses 9 Liabilities to sources of assets (shares) and revaluation reserves of the fund 90 – Monetary receipts 90x – Monetary receipts from contributions to members' personal accounts 90y – Monetary receipts from membership changes 90z – Monetary receipts from state incentives 93 – Monetary disbursements 93x – Monetary disbursements from pension payments 93y – Monetary disbursements from membership changes 93z – Monetary disbursements due to member's death 94 – Profit/loss of the current financial year 95 – Retained profit/loss from previous periods 96 – Fair value reserves 96x + 96y – fair value of financial assets 96z – Effective part of hedge accounting 990-994 – Active off-balance sheet records 995-999 – Passive off-balance sheet records

APPENDIX 2. FUND FINANCIAL STATEMENTS Form IFP STATEMENT OF FINANCIAL POSITION Fund name: _______________________________________ Fund OIB (Tax ID): _________________________________________ Pension company name: ____________________________ Reporting period: _________________________________ (in euros) Account group Position AOP Last day Previous financial years As of reporting date current period Fund Assets 10 + 18* Monetary funds 1 37 + 52 + 18* Deposits at credit institutions 2 55 + 18* Repo agreements and similar purchase/resale securities contracts 3 Transferable securities: (∑ AOP5 + AOP9) 4 30 + 32 + 40 + 41 + 18* – measured at fair value (∑ from AOP6 to AOP8) 5 a) traded on regulated market 6 b) traded on other regulated market 7 c) recently issued with prospectus providing for listing 8 50 + 18* – measured at amortized cost 9 31 + 51 Money market instruments 10 33x UCITS fund shares 11 33y Shares of funds similar to UCITS funds 12 34 AIF shares 13 35 Derivative financial instruments 14 55 Other financial assets 15 diff 1 (except cr 10) + 39 + 49 Other assets 16 Total Assets (AOP1 + AOP2 + AOP3 + AOP4 + (∑ from AOP10 to AOP16) 17 990-994 Off-balance sheet active records 18 Fund Liabilities 19 20 Liabilities from investments in financial instruments 20 21 + 28* Financial liabilities measured at fair value 21 22 + 28* Financial liabilities measured at amortized cost 22 23 Liabilities to the pension company 23 24 Liabilities to the depositary 24 26 Liabilities to share holders 25 25 + 27 + 28* Other fund liabilities 26 Total Fund Liabilities (∑ from AOP20 to AOP26) 27 Fund Net Assets (AOP17-AOP27) 28 Number of issued shares 29 Fund Share Price (AOP28/AOP29) 30 Fund Liabilities to Sources of Assets 31 90 Monetary receipts (AOP33 + AOP34 + AOP35) 32 90x Monetary receipts from contributions to members' personal accounts 33 90y Monetary receipts from membership changes 34 90z Monetary receipts from state incentives 35 93 Monetary disbursements (AOP37 + AOP38 + AOP39) 36 93x Monetary disbursements from pension payments 37 93y Monetary disbursements from membership changes 38 93z Monetary disbursements due to member's death 39 94 Profit/loss of current financial year 40 95 Retained profit/loss from previous periods 41 96 Fair value reserves (AOP43 + AOP44) 42 96x + 96y – fair value of financial assets 43 96z – effective part of hedge accounting 44 Total Liabilities to Sources of Assets (AOP32 + AOP36 + (Σ from AOP40 to AOP42) 45 995-999 Off-balance sheet passive records 46

• accrued interest on financial instrument Form ISD STATEMENT OF COMPREHENSIVE INCOME Fund name: _______________________________________ OIB: ______________________________________________ Reporting period: _________________________________ (in euros) Account group Position AOP Same period previous year Current period Net realized profits (losses) of financial instruments (AOP48 AOP49) 4 73 Realized gains from financial instruments 48 63 Realized losses from financial instruments 49 Net unrealized profits (losses) of financial instruments at fair value through profit or loss (AOP51 AOP52) 50 72-62 Net unrealized profits (losses) of financial instruments at fair value through profit or loss (adjustment to fair value) 51 71x-60x Net exchange differences of financial instruments at fair value through profit or loss 52 Other revenues (Σ from AOP54 to AOP58) 53 70 Interest revenues and amortization of premium (discount) 54 71 (except 71x) Positive exchange differences 55 74 Dividend revenues 56 75 Profit from reversal of impairment reserves for expected credit losses 57 76 Other revenues 58 Other financial expenses (Σ from AOP60 to AOP63) 59 67 Interest expenses 60 60 (except 60x) Negative exchange differences 61 64x Losses from impairment for expected credit losses 62 68 Other expenses from investments in financial instruments 63 Other expenses (Σ from AOP65 to AOP69) 64 61 Expenses from relations with the pension company 65 65 Depositary fee 66 66 Transaction costs 67 64y Impairment of other assets 68 69 Other permitted fund costs 69 Profit or Loss (AOP47 + AOP50 + AOP53 – AOP59 – AOP 64) 70 Other Comprehensive Income (AOP72 + AOP73 + AOP76) 71 Change in fair value of equity instruments 72 Change in revaluation reserves: debt securities (AOP74 + AOP75) 73 – unrealized gains/losses 74 – transferred to profit or loss (reclassification adjustments) 75 Change in revaluation reserves: hedge accounting (effective part) (AOP77 + AOP78) 76 – gains/losses 77 – transferred to profit or loss (reclassification adjustments) 78 Total Comprehensive Income (AOP70 + AOP71) 79

Form INTD STATEMENT OF CASH FLOWS (direct method) Fund name: _______________________________________ OIB: ______________________________________________ Reporting period: _________________________________ (in euros) Position Position Code Same period previous year Current period Cash flows from operating activities (Σ from AOP81 to AOP98) 80 Receipts from sale of transferable securities 81 Payments for purchase of transferable securities 82 Receipts from sale of money market instruments 83 Payments for purchase of money market instruments 84 Receipts from sale