CySEC Circular C642: Electronic Submission of RBSF Information for 2023

1 TO : Listed Companies: i. Companies that have securities listed on the regulated market of the Cyprus Stock Exchange and whose home member state is Cyprus (‘Local Listed Companies’) and ii. Companies that have securities listed on a regulated market of an EEA Country and whose home member state is Cyprus (‘International Listed Companies’). FROM : Cyprus Securities and Exchange Commission DATE : May 14, 2024 CIRCULAR No : C642 FILE No : 01.13.001.002.002 SUBJECT : Risk Based Supervision Framework (‘RBSF’) – Electronic submission of Information for the year 2023

The present Circular is issued pursuant to section 25(1)(c)(ii) & (iii) of the Cyprus Securities and Exchange Commission Law (‘the CySEC Law’).

1. Information requested by CySEC 1.1. CySEC requests from all Local Listed and International Listed Companies (‘The Listed Companies’), to complete Form RBSF-LLC and Form RBSF-ILC respectively (‘the Form (s)’) in the Appendix (here), regarding the electronic submission of information for the year 2023 and submit it only electronically via the CySEC’s Transaction Reporting System (‘TRS’), by June 10, 2024. 1.2. For the successful implementation of the RBS-F, it is imperative that all the information requested from the Listed Companies stated above, to be completed and submitted within the timeframes set. CySEC wishes to emphasise the importance of meeting the deadline set.
2. Additional Information Requested 2.1. Section General Information In this section, the following question is added: • Name of contact person with CySEC 2.2. Section A (Applies only to form RBSF-LLC) In this section, the following question is added:

2 • If the answer in question 1 is "SURVEILLANCE MARKET", please provide the reason for the issuer’s transfer to the Surveillance market. 2.3. Section B In this section, the following table is added: Composition of Internal Audit Committee Name Position (Chairman or Member) Executive or non Executive Independent or not independent 2.4. Section C of RBSF-LLC and Section D of RBSF-ILC In this section, the following question is added under question 5.2: • If your answer in question 5.2 is ‘YES’, please provide brief details and the number of the relevant disclosure note in the Financial Statements. 2.5. Section E of RBSF-LLC and Section F of RBSF-ILC In this section, the following risk category is added: • Climate Related Risk. 3. General Comments for Form RBSF-LLC and RBSF-ILC 3.1. The Form (s) will be available only in the English language. 3.2. The Form (s) should be completed based on the Audited Financial Statements of the Listed Company for the reporting period 01/01/2023 – 31/12/2023 and using 31/12/2023 as a reference date. In case that the Listed Company’s Audited Financial Statements have a different reporting period and thus a different reference date, an email to riskstatistics.listedcos@cysec.gov.cy should be sent, informing about the Listed Company’s different reporting period and requesting assistance as to how to complete the Form (s). 3.3. Amounts should be reported in Euro (€) (this is also indicated as the reporting currency in 'General Info' of the Form (s)). If the Listed Company’s Financial Statements are prepared in a currency other than Euro, the exchange rate provided at the following link should be used, in order to translate the amounts in Euro: www.ecb.int/stats/exchange/eurofxref/html/index.en.html#downloads under 'Time series for bilateral exchange rates', as at the reference date. The table below provides the actual exchange rates that should be used, in case that the Audited Financial Statements are prepared in the following currencies:

3 1Euro to (Exchange rate as at 31/12/20XX) Currency used in F.S 2023 2022 GBP –Pound Sterlin 0,86905 0,88693 USD- US dollar 1,1050 1,0666 3.4. Amounts should not be reported in abbreviations i.e. in thousands (‘000) or in millions (‘000.000). 3.5. The Form (s) must be submitted to CySEC as described in Section 5 below, by June 10, 2024. 4. Method of creating, signing and submitting the Form (s) to CySEC After populating the required Excel fields in the Form (s), the Listed Companies should name their Excel file in accordance to the following naming convention: Local Listed Companies: TRS username_yyyymmdd_RBSF-LLC International Listed Companies: TRS username_yyyymmdd_RBSF-ILC The information below explains the naming convention: i. TRS username - This codification should be entered in capital letters and it is exactly the same as the CySEC Portal Username (See Circular C200 for explanation). ii. yyyymmdd – this denotes the end of the reporting period of the Form (s). In this case the Form(s) should have a 20231231 format. Future Forms will have different reporting periods. In case of different reporting period, please refer to Section 2.2 above. iii. RBSF-LLC – this is the coding of the Form RBSF-LLC that remains unchanged and should be inserted exactly as it appears. Your attention is drawn to the fact that coding is a bit different from the name of the Form. iv. RBSF-ILC – this is the coding of the Form RBSF-ILC, which remains unchanged and should be inserted exactly as it appears. Your attention is drawn to the fact that coding is a bit different from the name of the Form. v. The Excel® must be of 2007 version and onwards. Excel will add the extension .xlsx as soon as it is saved. This extension should not under any circumstances, be inserted manually. Τhe fully completed excel form, which should be named based on the instructions explained in the paragraph above, must be submitted only electronically through the Transaction Reporting System (‘TRS System’), within the timeframes set. The steps that will have to be followed for the successful submission of the Form(s), can be found here.

4 5. Successful submission 5.1. Successful submission is considered only if the Listed Companies submit the Form (s) successfully through the TRS System and receive the positive feedback file that is dispatched on the Outgoing folder of the TRS System. 5.2. CySEC emphasises the importance of meeting the deadline of June 10, 2024. 5.3. Failure to promptly and duly comply with the above may bear the administrative penalties of section 37(5) of the CySEC Law. 6. Important Dates Summarised Dates Task May 10 2024 The Listed Companies can start submitting the digitally signed Form (s) to the CySEC’s TRS system. From May 10 until June 5, 2024 The Listed Companies can submit any queries that they have for this Circular and the Appendices attached. June 10, 2024 Deadline for submitting the Form(s) duly completed. 7. Support 7.1. Queries on how to complete the fields Should you have any queries on the completion of the fields of Form RBSF-LLC and RBSF-ILC, please submit them primarily in writing by sending an email to the address riskstatistics.listedcos@cysec.gov.cy until June 5, 2024 with subject ‘RBSF Listed companies 2023’ or by phone on 22-506600 and then selecting the option 6 and then 1. 7.2. Technical Queries on digitally signing and submitting the Form(s) For technical matters on digitally signing and submitting the Form (s), the Listed Companies are advised to frequently visit the CySEC’s dedicated section. For further clarifications, the Listed Companies are kindly advised to use the electronic address information.technology@cysec.gov.cy. All email communication with CySEC, should include in the subject, the Listed Company’s full name and the TRS username. Yours sincerely, Dr. George Theocharides Chairman, Cyprus Securities and Exchange Commission