Instructions for Preparing and Submitting Pension Insurance Company Reports in Electronic Form

Based on Article 15, point 7 of the Act on the Croatian Financial Services Supervisory Agency ("Narodne novine" nos. 140/05 and 12/12), the Croatian Financial Services Supervisory Agency, at the meeting of the Board of Directors held on February 4, 2025, adopts

INSTRUCTIONS FOR PREPARING AND SUBMITTING PENSION INSURANCE COMPANY REPORTS IN ELECTRONIC FORM

1. Introduction These instructions for preparing and submitting pension insurance company reports in electronic form (hereinafter: reports) define the format and method of submission thereof. The pension insurance company is obliged to submit monthly, quarterly, and annual reports to the Croatian Financial Services Supervisory Agency (hereinafter: Hanfa) in electronic form in accordance with the Act on Pension Insurance Companies ("Narodne novine" nos. 22/14, 29/18, 115/18, and 156/23; hereinafter: Act on Pension Insurance Companies) and the bylaws adopted based on it.

The appointed authorized actuary of the pension insurance company certifies the correctness of the data presented in certain solvency adequacy reports by preparing an explanation accompanying the quarterly and annual reports, and submits the Actuarial Function Report with the opinion of the appointed authorized actuary to Hanfa in electronic form together with the annual report, in accordance with the Act on Pension Insurance Companies and valid bylaws.

The pension insurance company, in the part of operations relating to the payment of pensions within the framework of voluntary pension insurance in accordance with the pension programs of the pension insurance company based on individual capitalized savings of a member of a closed voluntary pension fund (hereinafter: IORP), submits annual and quarterly quantitative information to Hanfa in electronic form, in accordance with EIOPA's Decision of the board of supervisors on EIOPA's regular information requests regarding provision of occupational pensions information (EIOPA-BoS-23-030).

2. Types of Reports The types of reports submitted electronically are:

3. Annual Report of the Pension Insurance Company (MOD_G);

4. Quarterly Report of the Pension Insurance Company (MOD_T);

5. Monthly Report of the Pension Insurance Company (MOD-MJESECNO);

6. Report on the Calculation of Asset Management Fees (MOD-IN-MJESECNO);

7. Actuarial Function Report with the opinion of the appointed authorized actuary accompanying the annual report (MOD-IMOA);

8. Quarterly Quantitative Information of IORP (QRI – Quarterly reporting Pension Funds individual);

9. Annual Quantitative Information of IORP (ARI – Annual reporting Pension Funds individual).

10. Structure of Reports Format of the report in electronic form and submission deadlines

Reports are submitted in electronic form in the following formats and files: • XML format file: MOD_G, MOD_T, MOD-MJESECNO, MOD-IN-MJESECNO which encompasses the reports prescribed by the Bylaw on Capital Adequacy of Pension Insurance Companies, the Bylaw on the Structure and Content of Financial and Additional Reports of Pension Insurance Companies, the Bylaw on Permitted Investments and Investment Limits for Assets Covering Technical Provisions of Pension Insurance Companies, and the Bylaw on Intervention Provisions in accordance with the scheme prescribed on Hanfa's website, signed exclusively by the management of the pension insurance company. This file constitutes the set of all financial and additional reports submitted within the Annual, Quarterly, and Monthly Reports of the pension insurance company and the Report on the Calculation of Asset Management Fees, excluding quantitative information for IORP.

• PDF format file: Management Explanation, signed by the management of the pension insurance company; This file is intended for the management explanations of the pension insurance company which may provide a separate statement, and in addition to the numerical data from financial and additional reports, provide text explanations within the Annual Report of the pension insurance company, the Quarterly Report of the pension insurance company, and the Report on the Calculation of Asset Management Fees, as well as for notes to financial reports.

• XLS format file: Analytical Presentation of Financial Liabilities from Asset Investments signed by the management of the pension insurance company; This file is intended for the submission of an analytical presentation of financial liabilities from asset investments to cover technical provisions for which the total assets covering technical provisions are reduced, or an analytical presentation of financial liabilities from asset investments to cover intervention provisions for which the total assets covering intervention provisions are reduced. The file is submitted together with the Report on the Calculation of Asset Management Fees.

• PDF format file: Explanation of the Appointed Authorized Actuary, signed by the appointed authorized actuary; This file contains the explanation of the appointed authorized actuary who certifies the correctness of the data contained in the following solvency adequacy reports: Report on the Calculation of the Solvency Margin of the Pension Insurance Company (form GS-MOD) and Report on the Capital Adequacy of the Pension Insurance Company (form AK-MOD), and data in the forms Statistical Data on Technical Provisions (form TP_MM-MOD) and Report on the Margin for Contracted Services (form ICSM-MOD). This file is also intended for other explanations of the appointed authorized actuary regarding other significant items used for calculation, data, differences in reports, etc., or for free text entry which may be of different shape, format, and length, with the possibility, but not the requirement, to include copies of tables or forms within them. The file Explanation of the Appointed Authorized Actuary is submitted within the Annual Report of the pension insurance company and the Quarterly Report of the pension insurance company.

• PDF format file: MOD-IMOA, Actuarial Function Report with the opinion of the appointed authorized actuary accompanying the annual report, signed by the appointed authorized actuary; This file represents the electronic form of the Actuarial Function Report with the opinion of the appointed authorized actuary in accordance with Article 99 of the Act on Pension Insurance Companies, which is submitted separately within 14 days from the date of submission of the annual report to Hanfa.

• XBRL format file: ARI, QRI which encompasses the set of annual and quarterly quantitative information in accordance with the XBRL Taxonomy developed by EIOPA, signed exclusively by the management of the pension insurance company. This file constitutes the set of all quantitative information within the annual and quarterly reporting submitted by IORPs.

4. Description of Report Files in PDF Format Report files in PDF format are intended for the submission of reports in free-format text.

5. Report Files in XML Format The pension insurance company is obliged to prepare report files in XML format in accordance with the prescribed Hanfa XML schema. The procedure by which the pension insurance company will convert report data into such a specified form is determined and implemented solely by the pension insurance company. XML schemas for preparing reports are published at the internet address: http://reports.hanfa.hr/Documentation

6. Report Files in XBRL Format IORPs are obliged to prepare report files in XBRL format in accordance with the valid XBRL Taxonomy developed by EIOPA. The procedure by which they will convert report data into such a specified form is determined and implemented solely by the pension insurance company. Information regarding the Data Point model and EIOPA XBRL Taxonomy is published on their websites.

7. Signing of Files The signing of files that the pension insurance company is obliged to submit is carried out in accordance with the valid Technical Instruction for the Application of Electronic Signature in the Reporting Procedure of the Croatian Financial Services Supervisory Agency.

8. Submission of Reports The reports from point 2 of these instructions are submitted by the pension insurance company in accordance with the valid Technical Instruction for the Use of the System for Data Submission in Electronic Form of the Croatian Financial Services Supervisory Agency at reports.hanfa.hr.

9. Final Provisions The rules for signing are the same as the rules applicable to the handwritten signature applied to the written form of the report. The Annual Report of the pension insurance company, the Quarterly Report of the pension insurance company, the Monthly Report of the pension insurance company, the Report on the Calculation of Asset Management Fees, and the annual and quarterly quantitative information of IORP are signed by at least two members of the management of the pension insurance company. Exceptionally, in case of impediment, the management of the pension insurance company may, in accordance with regulations on representation, authorize another person in writing to sign the reports with prior notice to Hanfa. The Explanation of the appointed authorized actuary certifying the correctness of data contained in solvency adequacy reports (Report on the Calculation of the Solvency Margin of the Pension Insurance Company (form GS-MOD) and Report on the Capital Adequacy of the Pension Insurance Company (form AK-MOD)) and the Actuarial Function Report with the opinion of the appointed authorized actuary accompanying the annual report is signed by the appointed authorized actuary. Exceptionally, in case of impediment, the appointed authorized actuary may, in accordance with regulations on representation, authorize another person in writing to sign the reports with prior notice to Hanfa. With these instructions, the Instructions for Preparing and Submitting Reports of Pension Insurance Companies in Electronic Form of December 21, 2022, cease to be valid. These instructions enter into force on the day of publication. CLASS: 011-01/25-04/01 FILE NUMBER: 326-01-50-53-531-25-1 Zagreb, February 4, 2025

CHAIRMAN OF THE BOARD OF DIRECTORS dr.sc. Ante Žigman