Decision on the Manner and Deadlines for Submitting Insider Lists

Croatian Financial Services Supervisory 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 Pursuant to the provisions of Article 15, point 4 and Article 8, paragraph 1 of the Act on the Croatian Financial Services Supervisory Agency (Official Gazette no. 140/05 and 12/12), Article 512 of the Capital Market Act (Official Gazette no. 65/18, 17/20, 83/21, 151/22, 85/24, 126/25 and 45/26) and Articles 1 and 2 of Commission Implementing Regulation (EU) 2026/1291 of 12 June 2026 laying down implementing technical standards for the application of Regulation (EU) No 596/2014 of the European Parliament and of the Council with regard to the format of insider lists and repealing Commission Implementing Regulation (EU) 2022/1210, the Croatian Financial Services Supervisory Agency, at the session of the Management Board held on 29 July 2026, adopts the DECISION ON THE MANNER AND DEADLINES FOR SUBMITTING INSIDER LISTS TO THE CROATIAN FINANCIAL SERVICES SUPERVISORY AGENCY General Provisions
Article 1.
This Decision prescribes the manner and deadlines for submitting insider lists to the Croatian Financial Services Supervisory Agency, which are compiled and updated in accordance with the provision of Article 18 of Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse (Market Abuse Regulation) and repealing Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC, and Commission Implementing Regulation (EU) 2026/1291 of 12 June 2026 laying down implementing technical standards for the application of Regulation (EU) No 596/2014 of the European Parliament and of the Council with regard to the format of insider lists and repealing Commission Implementing Regulation (EU) 2022/1210. Meaning of individual terms
Article 2.
For the purposes of this Decision, individual terms have the following meaning:
1. Hanfa is the Croatian Financial Services Supervisory Agency
2. Market Abuse Regulation is Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April 2014 on market abuse (Market Abuse Regulation) and repealing Directive 2003/6/EC of the European Parliament and of the Council and Commission Directives 2003/124/EC, 2003/125/EC and 2004/72/EC
3. Implementing Regulation (EU) 2026/1291 is Commission Implementing Regulation (EU) 2026/1291 of 12 June 2026 laying down implementing technical standards for the application of Regulation (EU) No 596/2014 of the European Parliament and of the Council with regard to the format of insider lists and repealing Commission Implementing Regulation (EU) 2022/1210
4. Issuer is a legal entity as prescribed by Article 3, paragraph 1, point 21 of the Market Abuse Regulation
5. Insider list is a list that issuers or any persons acting on their behalf or on their account are obliged to compile and update in accordance with the provisions of Article 18 of the Market Abuse Regulation and Implementing Regulation (EU) 2026/1291.
Insider Lists
Article 3.
The issuer compiles the insider list in the content prescribed by Implementing Regulation (EU) 2026/1291, which consists of the following templates:
– Template 1 - Format of insider lists from Article 1, paragraph 1 of Implementing Regulation (EU) 2026/1291 and – Template 2 - Format for the section of permanent insiders in insider lists from Article 1, paragraph 2 of Implementing Regulation (EU) 2026/1291. Deadlines for submitting insider lists
Article 4.
The issuer is obliged to submit the valid insider list and all its eventual changes to Hanfa within the following deadlines:
1. no later than January 15 of the current year for the period from October 1 to December 31 of the previous year
2. no later than April 15 of the current year for the period from January 1 to March 31 of the current year
3. no later than July 15 of the current year for the period from April 1 to June 30 of the current year
4. no later than October 15 of the current year for the period from July 1 to September 30 of the current year.
Form of submission of insider lists
Article 5.
(1) The issuer is obliged to submit the insider list from Article 3 of this Decision to Hanfa as an XML format file.
(2) The XML file from paragraph 1 of this Article is created in accordance with the technical package that Hanfa publishes on its website, which includes an XSD schema. The XML file can be created via Hanfa's web interface or another tool of choice. Method of submission of insider lists
Article 6.
(1) The issuer is obliged to submit the insider list from Article 3 of this Decision to Hanfa's reporting system using the appropriate interface on Hanfa's website (https://reports.hanfa.hr/), all in accordance with Hanfa's rulebook regulating the content, form, and method of submitting prescribed information to Hanfa and to the official register of prescribed information (SRPI), and the accompanying technical instruction from Hanfa for those obliged to submit prescribed information to SRPI and Hanfa, which Hanfa publishes on its website. (2) For submitting insider lists to Hanfa's reporting system (https://reports.hanfa.hr/), the issuer uses the authorizations granted to them for submitting data to SRPI. Transitional and Final Provisions
Article 7.
(1) The issuer is obliged to compile and submit the data from Article 3 of this Decision in accordance with the provisions of this Decision for periods starting from July 1, 2026.
(2) This Decision enters into force on the day of its adoption and will be published on Hanfa's website.
(3) Upon the entry into force of this Decision, the Decision on the Manner and Deadlines for Submitting Insider Lists of January 19, 2023 (CLASS: 011-02/23-01/04, URBROJ: 326-01-60-62-23-1) ceases to be valid. CLASS: 011-01/26-01/03 URBROJ: 326-01-60-62-26-1 Zagreb, July 29, 2026. DEPUTY CHAIRWOMAN OF THE MANAGEMENT BOARD Anamarija Staničić