Decision on the Method for Drawing Up a Voluntary Winding-up Plan and the Content of Notification on the Course of Voluntary Winding-up Proceedings

Pursuant to Article 44 paragraph 2 item 3 of the Central Bank of Montenegro Law (OGM 40/10, 6/13, 70/17, 125/23), Article 56a paragraph (12) and Article 56b paragraph (6) of the Law on Bankruptcy and Winding Up of Banks a.k.a. Bank Bankruptcy and Liquidation Law (OGRM 047/01,OGM 062/08, 044/10, 072/19, 113/24, 089/25), the Council of the Central Bank of Montenegro, at its meeting held on 15 September 2026, passed the following DECISION ON THE METHOD FOR DRAWING UP A VOLUNTARY WINDING-UP PLAN AND THE CONTENT OF NOTIFICATION ON THE COURSE OF VOLUNTARY WINDING￾UP PROCEEDINGS Subject matter
Article 1
This decision governs in more detail the conditions and the manner under which the bank, intending to pass a decision on termination of operations of the bank, draws up a voluntary winding-up plan, and the content of notification on the course of voluntary winding-up proceedings that is submitted to the Central Bank of Montenegro (hereinafter:
the Central Bank).
Voluntary winding-up plan
Article 2
(1) The voluntary winding-up plan shall, as a minimum, contain:

1. the planned date of convening the general meeting of shareholders of the bank at
   which the decision on the termination of the bank’s operations is to be adopted, and the planned date of commencement of the voluntary winding-up proceedings;

2. an explanation of the reasons for the termination of the bank’s operations, or the
   intention to initiate voluntary winding-up proceedings;

3. information on whether other options concerning the termination of the bank’s
   operations have been considered, including communication with potential acquirers or the implementation of corporate transformations in accordance with the law governing the operation of credit institutions;

4. an assessment of whether the bank meets the liquidity and solvency requirements
   in accordance with the law governing the operation of credit institutions, accompanied by evidence confirming that the bank has sufficient funds to repay deposits, in particular to repay covered deposits within seven working days from the date of commencement of the voluntary winding-up proceedings, as well as evidence that the bank has sufficient assets to fully satisfy all remaining creditors and cover the costs of the proceedings;

5. a plan for the bank’s communication with creditors, in particular with depositors,
   for the purpose of repaying deposits, especially covered deposits;

6. an assessment of the manner of liquidation of assets, including a strategy and
   timeline for the collection of receivables, a description of the procedure for the sale of tangible and intangible assets, specifying the assets to be sold, whether encumbered by security interests or unencumbered, and the intended use of the proceeds generated from such sales;

7. the report on maturity structure of assets and liabilities by remaining maturities;

8. the total amount of covered deposits and the total number of depositors whose
   deposits are covered, as well as the manner in which covered deposits will be repaid in accordance with the law;

9. the total amount of deposits which, within the meaning of the law governing deposit
   protection, are not considered covered deposits, the number of depositors whose deposits are not considered covered, as well as the plan and timeline for their repayment; 10)a communication plan for customers to whom the bank provides transaction account and payment services, including a timeline for closing accounts and notifying customers who receive salaries, pensions or social benefits through the bank, or who have standing orders and direct debits in place;

10. a communication and settlement plan with banks in Montenegro and abroad
    (including correspondent banks), other financial institutions, and operators of payment systems, card payment schemes and other financial market infrastructures in which the bank participates;

11. a plan for closing or transferring the bank’s off-balance-sheet liabilities to other
    banks or financial institutions;

12. a plan for handling collateral instruments received by the bank (bills of exchange,
    pledges, mortgages, fiduciary arrangements and similar instruments) and returning such instruments to clients following settlement of their obligations;

13. a plan for the settlement of obligations towards creditors who are not depositors,
    including an overview of all collateral instruments pledged by the bank to such creditors, a description of the type of such instruments, an assessment of their value, as well as a detailed list of identified creditors, in order of priority and payment ranking in accordance with the Law on Bankruptcy and Winding Up of Banks;

14. a plan for the early and accelerated collection of cash receivables during the
    winding-up, including the conditions for out-of-court settlements;

15. an assessment of the outcome and financial impact of all pending and potential
    future court proceedings in which the bank is a party, including, in particular, the determination of provisions for lawsuits in which the bank is the defendant;

16. the manner in which the bank’s operations will be organised, including the costs
    of terminating employment contracts with employees and other business arrangements (outsourced services, consultancy services and similar arrangements), and a plan for retaining the positions necessary for the operation of the bank during the voluntary winding-up, clearly identifying such positions;

17. the expected duration of the voluntary winding-up proceedings, including, where
    applicable, the deadlines for implementing individual elements of the plan referred to in this paragraph;

18. financial projections for the entire planned duration of the winding-up proceedings,
    comprising a projected income statement, a projected balance sheet, and a detailed quarterly cash flow forecast for the expected duration of the voluntary winding-up proceedings;

19. the bank’s public communication plan.
    (2) Until the Central Bank adopts a decision approving the voluntary winding-up plan, and no later than the adoption of the decision on the termination of the bank’s operations, the general meeting of shareholders of the bank may, with the consent of the bank’s management board, adopt a decision to withdraw the intention to initiate voluntary winding-up proceedings, including the withdrawal of the plan referred to in paragraph (1) of this Article. (3) The bank shall submit the decision on the withdrawal referred to in paragraph (2) of this Article to the Central Bank no later than three days from the date on which the decision is adopted by the general meeting of shareholders. Notification on the course of voluntary winding-up proceedings
    Article 3
    (1) The liquidator shall submit to the Central Bank a monthly report on the progress of the voluntary winding-up proceedings within 15 days from the end of the month to which the report relates. (2) The report referred to in paragraph (1) of this Article shall contain detailed information and data on the implementation and degree of completion of the voluntary winding-up plan, and in particular:

20. a cash flow statement, presenting all cash inflows and outflows realised, including
    the opening and closing account balances;

21. a statement of financial position (interim balance sheet, income statement and off￾balance-sheet records) prepared in accordance with the Central Bank regulation
    governing the financial reporting of credit institutions;

22. a report on the liquidation of the bank’s assets and the collection of its receivables,
    presenting the assets sold and the realised sale prices compared to their estimated fair value;

23. a report on the status of deposits and outstanding liabilities, containing an updated
    number of depositors and other creditors, including the outstanding liabilities towards all classes of the bank’s creditors, with a separate presentation of the covered deposit base. Entry into force
    Article 4
    This Decision shall enter into force on the eighth day following that of its publication in the “Official Gazette of Montenegro”.

THE COUNCIL OF THE CENTRAL BANK OF MONTENEGRO CHAIRPERSON G O V E R N O R Irena Radović m.p. Decision no. 0101-6963-8/2026 Podgorica, 15 September 2026