Insider information

Obligations and sanctions regarding the misuse of insider information are prescribed by the Law on the Capital Market.

Insider information is information about specific facts that have not been publicly disclosed, relate directly or indirectly to NIS a.d. Novi Sad or securities issued by NIS a.d. Novi Sad, which, if they were disclosed, would probably have a significant impact on the price of these securities.

OBLIGATIONS OF THE PERSON IN POSSESSION OF INSIDER INFORMATION

A person to whom insider information is available is any person who possesses insider information through:

• membership in the Management Board of NIS a.d. Novi Sad;
• share in the NIS a.d. Novi Sad capital;
• performing duties in the workplace, performing a profession or duties;
• criminal offences,

(„person with special responsibility“),
as well as any other person who has insider information if they know or should have known that it is insider information.

A person to whom insider information is available is prohibited from:

• trading, attempting to trade, recommend, encourage or assist another to trade on the basis of insider information;
• unlawfully disclosing insider information, except when this information is disclosed as part of the normal performance of a job, profession or duties;
• encouraging another person or helping them to unlawfully disclose insider information.

The fact that a person possesses insider information does not imply that the person in question has used that information or traded based on it. However, if the Securities Commission finds that there was an illegal reason for trading, transactions or procedures, it can be considered that there was a violation of the prohibition on trading based on insider information.

The Securities Commission shall supervise the misuse of insider information. Here you can find information on sanctions for using, disclosing, making available or recommending insider trading and penalties for non-compliance.

ADDITIONAL OBLIGATIONS FOR THE PERSON PERFORMING THE DUTIES OF THE MANAGER AND ASSOCIATED PERSONS

The person performing the duty of the manager is:

• a member of the Management Body of NIS a.d. Novi Sad;
• an executive who has regular access to insider information directly or indirectly related to NIS a.d. Novi Sad, as well as the possibility of making decisions that may affect the future development of events and business prospects of NIS a.d. Novi Sad.

The person associated with the person performing the duty of the manager is:

• a spouse and a person who, in accordance with the law, can be considered a spouse;
• a supported minor, in accordance with the law;
• a relative who lived in a community with that person for at least one year before the date of execution of the transaction;
• a legal person, trust or partnership managed by a person performing the manager duties or directly or indirectly controlled by them, which is established for their benefit, or a person whose economic interest is significantly similar to the interest of that manager.

Obligation of transaction notification

The manager or a related party shall notify the Securities Commission after the total amount of transactions in one calendar year reaches the threshold of EUR 5,000 of each subsequent transaction within 3 working days from the date of the transaction. The notification of transactions shall be made on the form of the Securities Commission „INS 22“ in electronic form in PDF format with the signature of a qualified electronic certificate* through the portal of the Securities Commission.

The transaction reporting procedure using the portal includes several steps. For more information, please contact obveznice@nis.rs.

The Commission shall make the submitted data publicly available in the Official Register of Information on its website.

The period of prohibition of trading for managers

The person performing the duties of the manager is prohibited from trading in securities of NIS a.d. Novi Sad 30 days before the publication of the annual, semi-annual and quarterly financial statements of NIS a.d. Novi Sad (calendar with an overview of the prohibition period). Exceptionally, NIS a.d. Novi Sad may allow the sale during the prohibition period if there are exceptional circumstances requiring an urgent sale.

*Detailed information on the issuers of a qualified electronic certificate can be found at: https://mit.gov.rs/tekst/583/registar-pruzalaca-kvalifikovanih-usluga-od-poverenja-.php