OF SUMMA LINGUAE TECHNOLOGIES SPÓŁKA AKCYJNA WITH … · Kommunicera AS based in Lingtech A/S...

INFORMATION POLICY

OF SUMMA LINGUAE TECHNOLOGIES SPÓŁKA AKCYJNA WITH ITS SEAT IN KRAKÓW

This Information Policy of Summa Linguae Technologies Spółka Akcyjna [a Polish joint-stock company]

with its registered office in Kraków (“Summa Linguae Technologies”, the “Company”) was introduced

by the Management Board of the Company by virtue of the resolution of 27 March 2017, in connection

with the entry into force on 3 July 2016 of Regulation (EU) No 596/2014 of the European Parliament

and of the Council of 16 April 2014 on market abuse (the MAR 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 (Text with EEA relevance) (hereinafter the “MAR Regulation”) and

updated on 31 January 2018, 27 November 2018, 24 September 2019 and 9 January 2020 in

connection with the changes to the composition of the Company’s Capital Group.

The Summa Linguae Technologies Information Policy specifies the manner in which the Company is to

comply with its information obligations, including in particular those related to inside information

published by the Company, developed to the best of the Company’s knowledge and will.

This Information Policy is intended to ensure that information obligations are fulfilled in accordance

with the currently applicable laws.

The catalogue of events presented below is of an open nature, and like the scope of information on

such events that must be disclosed – it may be expanded in relation to a given event, if it were to

affect the assessment of a given event by a reasonable investor. If the given event / circumstance was

not included in this Information Policy but meets the definition of inside information set forth in the

MAR Regulation, the Company undertakes to publish such information.

General principles of the Information Policy

1. Summa Linguae Technologies implements its Information Policy in a spirit of open and

transparent communication, ensuring equal access to accurate and complete information

about the Company to shareholders, investors, the media, and all interested parties.

2. Upon implementing its Information Policy, Summa Linguae Technologies follows the

confidentiality and information security requirements imposed on the Company under the

law, being a public company.

3. Summa Linguae Technologies is committed to ensuring that access to information takes into

account the needs of its shareholders, customers and the general public and that such access

is equal to all interested parties and that is provided in compliance with the law.

4. The Company’s Information Policy takes into account the provisions contained in the MAR

Regulation and the Polish legal order. The most important laws and regulations affecting the

Summa Linguae Technologies Information Policy are:

a) the MAR Regulation;

b) Commission Implementing Regulation (EU) 2016/347 of 10 March 2016 laying down

implementing technical standards with regard to the precise format of insider lists and for

updating insider lists in accordance with Regulation (EU) No 596/2014 of the European

Parliament and of the Council (Text with EEA relevance);

c) Commission Implementing Regulation (EU) 2016/523 of 10 March 2016 laying down

implementing technical standards with regard to the format and template for notification and

public disclosure of managers' transactions in accordance with Regulation (EU) No 596/2014

of the European Parliament and of the Council;

d) Commission Implementing Regulation (EU) 2016/378 of 11 March 2016 laying down

implementing technical standards with regard to the timing, format and template of the

submission of notifications to competent authorities according to Regulation (EU) No

596/2014 of the European Parliament and of the Council;

e) Commission Implementing Regulation (EU) 2016/959 of 17 May 2016 laying down

implementing technical standards for market soundings with regard to the systems and

notification templates to be used by disclosing market participants and the format of the

records in accordance with Regulation (EU) No 596/2014 of the European Parliament and of

the Council;

f) Commission Implementing Regulation (EU) 2016/1055 of 29 June 2016 laying down

implementing technical standards with regard to the technical means for appropriate public

disclosure of inside information and for delaying the public disclosure of inside information in

accordance with Regulation (EU) No 596/2014 of the European Parliament and of the Council;

g) Code of Commercial Companies and Partnerships;

h) Act of 29 July 2005 on public offer and conditions for the introduction of financial instruments

to an organized trading system and on public companies;

i) Act of 29 July 2005 trading in financial instruments;

j) Act of 29 July 2005 on capital market supervision;

k) Annex 3 to the Alternative Trading System Rules;

l) Relevant resolutions of the Management Board of the Warsaw Stock Exchange and the Polish

Financial Supervision Authority;

m) Code of Best Practice for Companies Listed on the NewConnect Market;

n) General Reporting Standard Guidelines: OSR-1 (Financial Data Reporting) and OSR-2 (Current

Inside Information Reporting).

Definitions

“Company” or “Summa Linguae Technologies” - Summa Linguae Technologies S.A. with its seat in

Kraków, address: ul. Josepha Conrada 63, 31-357 Kraków, NIP (Tax ID): PL 945 -216-57 Kraków, entered

into the Register of Businesses maintained by the District Court for Kraków-Śródmieście in Kraków, XI

[11th] Commercial Division of the National Court Register under KRS No. 400208;.

“Summa Linguae Romania” – Summa Linguae Romania s.r.l., based in Bucharest (Romania), a

subsidiary of Summa Linguae Technologies.

“Mayflower” – Mayflower Language Services Pvt Ltd, based in Bengaluru (India), a subsidiary of

Summa Linguae Technologies.

“Kommunicera” – Kommunicera Communications AB based in Gothenburg, or Kommunicera AS based

in Oslo, or Lingtech A/S based in Stenløse – subsidiaries of Summa Linguae Technologies.

“GlobalMe” - GlobalMe Localizations Inc., based in Vancouver, Canada, a subsidiary of Summa Linguae

Technologies.

“GlobalVisio” - GlobalVision International Inc., based in Westborough, Massachusetts (United States

of America), a subsidiary of Summa Linguae Technologies.

“Company's Capital Group” – Company together with its subsidiaries. The Company's Capital Group

is compsed of: Summa Linguae Romania s.r.l. based in Bucharest (Romania), Mayflower Language

Services Pvt Ltd based in Bengaluru (India), Kommunicera Communications AB based in Gothenburg,

Kommunicera AS based in Lingtech A/S based in Stenløse, GlobalMe Localizations Inc. based in

Vancouver (Canada) and GlobalVision International Inc. based in Westborough, Massachusetts

(United States of America).

“Inside Information” - under Article 7 of the MAR Regulation, it is information: a) of precise nature,

b) which has not been made public, c) relating directly or indirectly to one or more issuers or to one

or more financial instruments, and d) which, if it were made public, would be likely to have a significant

effect on the prices of those financial instruments or the price of related derivative financial

instruments (price formation nature).

“Person discharging managerial responsibilities” – means a person within the Company, who is a) a

member of the administrative, management or supervisory body, or b) is a senior executive who is

not a member of the bodies referred to in a), who has regular access to inside information relating

directly or indirectly to the Company and power to take managerial decisions affecting the future

developments and business prospects of the Company.

“Person closely associated” - a) a spouse, or a partner considered to be equivalent to a spouse in

accordance with national law; b) a dependent child, in accordance with national law; c) a relative who

has shared the same household for at least one year on the date of the transaction concerned; or d)

a legal person, trust or partnership, the managerial responsibilities of which are discharged by a

person discharging managerial responsibilities or by a person referred to in points a), b) or c), which

is directly or indirectly controlled by such a person, which is set up for the benefit of such a person, or

the economic interests of which are substantially equivalent to those of such a person

“Significance” - “significant” or “material” (terms used interchangeably) are considered to be,

a) until the date of publication of the first consolidated financial statements of the Company's

Capital Group – information concerning data relating to the value of not less than 10% of the

Company’s equity, shown in the most recent published financial statements of the Company,

as well as information as a result of which effects will arise or may be reasonably expected to

arise concerning data or values relating to the above level (“Significance Threshold”);

b) from the date of publication of the first consolidated financial statements of the Company’s

Capital Group – information concerning data relating to the value of not less than 10% of the

value of the Company’s Capital Group’s consolidated equity shown in the last published

consolidated financial statements of the Company’s Capital Group, as well as information as a

result of which effects will arise or may be reasonably expected to arise concerning data or

values relating to the aforementioned level (“ Significance Threshold 2”).

“Material Agreement” - an agreement whose value equals or exceeds 10% of the consolidated equity

of the Company’s Capital Group. The value of consolidated equity of the Company's Capital Group is

understood as the value shown in the last published consolidated financial statements of the

Company’s Capital Group. The value of the consolidated equity of the Company’s Capital Group is

updated on a quarterly basis, following the publication of periodic reports by the Company.

“Material Assets” – assets whose value is not less than the Significance Threshold.

Inside Information

1. The classification of a piece of information as Inside Information should be made on a case-

by-case basis, taking into account all the characteristics of the piece of information concerned

and the situation and event to which it relates.

2. The Company makes the Inside Information available to the public in a manner that enables

quick access and full, correct and timely evaluation of information by the public.

3. Information classified as inside information is to be immediately published in a report. In the

event of any doubts it is assumed that the duty to publish the report arises immediately after

the Company becomes aware of the occurrence of the events or circumstances which justify

the publication of such information.

4. The Company publishes inside information through:

a) Electronic Information Database (EID) – all current and periodic reports, except for current

reports provided through the EIES referred to in point b) below;

b) Electronic Information Exchange System (EIES) – other reports, including reports on Inside

Information and delays of Inside Information;

c) the Company’s website www.summalinguae.pl. in particular in the section entitled “Investor’s

relations”.

Specific provisions on Inside Information

1. The Company is required to make a current report public, if the Company, Summa Linguae

Romania, Mayflower, Kommunicera, GlobalMe or GlobalVision enter into a Material

Agreement.

2. The Company considers an agreement to be a Material Agreement in particular:

a) for agreements concluded for a fixed period of time, shorter than 1 year – any agreement

whose total or estimated value is no lower than the Significance Threshold;

b) for agreements concluded for an unlimited period of time or for a fixed time longer than 12

months – any agreement whose total or estimated value of performances under such an

agreement over a period of 12 months is no lower than the Significance Threshold;

c) for master cooperation agreements, whose value cannot be estimated by the Company’s

Management Board – any master agreement after the value of the orders submitted to the

Company for completion under the given master agreement over a period of 12 months of its

duration exceeds the Significance Threshold;

3. Irrespective of the Significance Threshold, the Company is obliged to publish a current report

if the Company, Summa Linguae Romania, Mayflower, Kommunicera, GlobalMe, or

GlobalVision conclude an agreement whose value is lower than the Significance Threshold,

but it has a significant impact on the commercial, property and financial situation of the

Company or concerns the Company’s perspectives of future development.

Catalogue of events recognised to be Inside Information

1. The Management Board of the Company has developed a catalogue of potential inside

information that should be treated as Inside Information by the persons discharging

managerial responsibilities, unless there are circumstances that exclude the prerequisites for

treating the event as Inside Information. The events listed below do not form an exhaustive

list.

2. Any event that is not on the list that meets the criteria of Inside Information will be qualified

by the Company as Inside Information and will be immediately made public.

3. In particular, the following events /circumstances concerning the operations of the Company

http://www.summalinguae.pl/

/ the Company's subsidiary will be recognised as Inside Information:

1. acquisition or disposal by the Company or by its subsidiary of Material Assets;

2. loss of Material Assets by the Company or by its subsidiary;

3. the conclusion by the Company or by its subsidiary of a Material Agreement or awarding

the status of a Material Agreement to any agreement concluded by the Company or by its

subsidiary;

4. fulfilling or failing to fulfil a condition concerning a Material Agreement that is conditional

in nature concluded by the Company or by its subsidiary;

5. terminating or dissolving an agreement concluded by the Company or by its subsidiary

which, at the time it is terminated or dissolved, is a Material Agreement;

6. restructuring or reorganisation activities that have or will have an impact on the

Company’s Material Assets and liabilities, and the Company's economic, financial

condition or its profits and losses;

7. significant changes in the value of the Company’s assets;

8. physical destruction of goods that constitute significant components of the Company's

assets (both in terms of value and usefulness in the Company’s operations);

9. creation of significant intangible assets within the Company's assets, including in

particular: new licenses, patents, registered trademarks, the significance of which is

assessed by taking into account the projected costs and revenues from their acquisition;

10. significant reduction in the value of patents or rights or other intangible assets;

11. creation of significant innovative products or processes in the course of the Company’s

activities;

12. significant decrease or increase in the value of financial instruments held by the Company;

13. the Company's decision to withdraw from or enter into a new area of primary activity;

14. making a decision concerning a significant change in the Company’s investment policy;

15. establishment of a mortgage, a pledge or other limited right in rem on the Material Assets

by the Company or by its subsidiary;

16. adoption of a new development strategy for the Company or the Company’s Capital Group

or introducing significant changes to the previously announced strategy;

17. deciding to issue bonds where the value of the issued bonds exceeds the Significance

Threshold, and in the case of an issue of bonds convertible into shares, bonds with pre-

emptive right and revenue bonds;

18. cancellation or liquidation of lines of credit by one or more banks if their value exceeds

the Significance Threshold;

19. making a decision to issue shares of the Company or other securities of the Company;

20. purchase or sale by the Company of securities issued by the Company if the value of such

securities exceeds the Significance Threshold;

21. granting by the Company or its subsidiary for the benefit of one or more related entities a

surety for a loan or bank loan or granting a guarantee if the value of such surety or

guarantee exceeds the Significance Threshold;

22. initiation of proceedings before a court, arbitration authority or public administration

authority concerning liabilities or receivables of the Company or its subsidiary, if the value

of potential claims exceeds the Significance Threshold;

23. deciding on: intention to submit a petition for bankruptcy declaration or for initiation of

restructuring proceedings, submission of a petition for bankruptcy declaration; dismissal

of the petition for bankruptcy declaration, if the assets of the debtor are not sufficient to

satisfy the costs of the bankruptcy declaration; opening of restructuring proceedings;

acceptance of an arrangement in restructuring proceedings; conclusion or discontinuation

of bankruptcy or restructuring proceedings - in relation to the Company or its subsidiary;

24. the Company’s acquisition of verified information on concluded agreements concerning

exercising or taking control over the Company;

25. preparation of forecasts or estimates of the Company’s or the Company’s Capital Group’s

financial results, if the Company has decided to publish them and any significant changes

to the forecasts or estimates of the Company’s or the Company’s Capital Group’s financial

results published earlier;

26. granting or changing the rating granted at the Company’s request;

27. learning about the insolvency of significant debtors of the Company;

28. materialisation of risks related to the Company’s operations, in particular decisions

concerning the creation and release of material reserves;

29. court registration of a change in the amount or structure of the Company’s share capital;

30. change of rights from the Company’s securities;

31. cancellation of the Company's shares;

32. making a decision on merging the Company with another entity and combining the

Company with another entity;

33. making a decision on the division of the Company and performing the division of the

Company;

34. making a decision to transform the Company and transforming the Company;

35. selection by a competent authority of the Company of an entity authorised to audit

financial statements with whom an agreement on reviewing or auditing is to be

concluded, and termination by the Company or by such entity authorised to audit financial

statements of such an agreement on reviewing or auditing, as well as termination of such

an agreement by mutual consent;

36. dismissal or resignation of the managing or supervising person or the Company becoming

aware of the decision of the managing or supervising person to resign from applying for

election in the next term;

37. appointment of a managing or supervising person in the Company;

38. completion of subscription or sale procedure related to the introduction of securities of

the Company into trading;

39. admission or refusal to admit the Company’s securities to trading;

40. being listed on the territory of a country which is not a Member State of the European

Union;

41. information on convening and holding of the General Meeting of the Company;

42. decisions concerning the share buy-back programmes or transactions on other listed

financial instruments;

43. adoption of the Company’s dividend policy or amendments thereto, if such dividend policy

has been adopted earlier.

Reporting of current Inside Information – scope of information

1. Acquisition or disposal of Material Assets:

In the event of acquisition or disposal of Material Assets, a report will be published that contains in

particular the following information:

a) identification of the parties to the agreement under which the acquisition or disposal

of assets took place;

b) date and manner of acquisition or disposal of assets;

c) basic characteristics of the assets acquired or disposed of;

d) the price at which the assets were acquired or disposed of and the book value of those

assets in the books of the Company or its subsidiary;

e) the criterion for recognising that the given assets are Material Assets;

f) in the case of acquisition of assets – the source of financing for the acquisition of assets

and indication of the valuation of the assets in question, together with indication of

the key assumptions of such valuation, if the valuation was carried out by an

independent entity, together with the indication of that independent entity;

g) the reason behind the decision to acquire or dispose of the assets concerned;

h) if the agreement on the acquisition or disposal of the Material Assets is an agreement

with a related entity – additionally, a description of the Company’s or its subsidiary’s

relations with the seller or purchaser, and a detailed description of the terms of this

agreement;

i) in case of acquisition or disposal of shares (either in a joint-stock company or a limited

liability company) – additionally the name (business name) of the entity whose shares

(either in a joint-stock company or a limited liability company) are the subject of

acquisition or disposal, their share in the share capital of this entity and the nominal

value of these assets and their nature as a long-term or short-term capital investment

of the Company or its subsidiary, as well as the share of the Company or its subsidiary

in the share capital and the number of votes held at the general meeting of

shareholders of the entity whose shares (either in a joint-stock company or a limited

liability company) were acquired or disposed of;

j) other circumstances relating to the event in question that are important from the

viewpoint of the Company.

2. Loss of Material Assets by the Company or by its subsidiary

In the event of a loss by the Company or its subsidiary of Material Assets a report will be published

that contains in particular the following information:

a) name (business name) of the entity involved;

b) date of the event;

c) nature of the event;

d) description of lost assets;

e) book value and estimated market value of lost assets;

f) description of anticipated effects of loss of assets on the Company's or its subsidiary's

and the Company's Capital Group's continued business operations;

g) the criterion for recognising that the given assets are Material Assets;

h) other circumstances relating to the event in question that are important from the


3. Conclusion by the Company or by its subsidiary of a Material Agreement or

awarding the status of a Material Agreement to any agreement concluded by

the Company or by its subsidiary

If the Company or its subsidiary enters into a Material Agreement a report will be published that

contains in particular the following information:

a) date of the Agreement;

b) identification of the parties to the Agreement;

c) identification of the subject-matter of the Agreement;

d) material terms and conditions of the Agreement, with particular emphasis on the

financial terms and conditions of the Agreement, and an indication of the specific

terms and conditions indicated by the parties, specific to the Agreement, in particular

those deviating from the terms and conditions commonly used for the given type of

an agreement;

e) in the case of concluding an agreement subject to a condition or a term - the condition

or term reserved in that agreement, indicating whether it is a condition precedent or

a condition subsequent;

f) identification of the criteria in line with which the given agreement is to be recognised

as a material agreement, in particular taking into account the rules laid down in this

Information Policy;

g) other circumstances relating to the event in question that are important from the


4. Fulfilling or failing to fulfil a condition concerning a Material Agreement that is

conditional in nature concluded by the Company or by its subsidiary

If a condition concerning a Material Agreement concluded by the Company or its subsidiary is fulfilled,

a report will be published that contains in particular the following information:

a) identification of the parties to the Agreement;

b) identification of the subject-matter of the Agreement;

c) contents of the condition or the term for the Agreement's performance;

d) information on whether the indicated condition was met, along with the reasons for

this;

e) other circumstances relating to the event in question that are important from the


5. Terminating or dissolving an agreement concluded by the Company or by its

subsidiary which, at the time it is terminated or dissolved, is a Material

Agreement

If the Company or its subsidiary terminates or dissolves a Material Agreement concluded by them a

report will be published that contains in particular the following information:

a) identification of the parties to the agreement;

b) the date of termination of the agreement along with the date of dissolution of the

agreement;

c) identification of the subject-matter of the agreement;

d) the reasons for terminating the agreement, indicating the party terminating it;

e) description of the anticipated financial consequences, resulting from the termination

of the agreement, for the Company or the Company’s Capital Group;

f) other circumstances relating to the event in question that are important from the


6. Restructuring or reorganisation activities that have or will have an impact on the

Company’s Material Assets and liabilities, and the Company's economic,

financial condition or its profits and losses

If restructuring or reorganisation activities are planned that have or will have an impact on the

Company’s Material Assets and liabilities and its economic, financial situation or on profits and losses


a) description of planned restructuring or reorganisation measures;

b) reasons for adopting these plans;

c) planned implementation deadlines;

d) expected effects of the planned activities;



7. Significant changes in the value of the Company’s assets

In the event of significant changes in the value of the Company’s assets a report will be published that


a) indication of reasons for such significant changes in the value of assets;

b) determination of the current carrying amount of the assets in question and the value of

those assets after the change;

c) other circumstances relating to the event in question that are important from the


8. Physical destruction of goods that constitute significant components of the Company's

assets (both in terms of value and usefulness in the Company’s operations)

In the case of physical destruction of goods constituting significant components of the Company's

assets (both in terms of value and usefulness in conducting business activity by the Company) a report

will be published that contains in particular the following information:

a) indication of the reasons for the physical destruction of goods constituting significant

components of the Company’s assets;

b) determination of the value of the destroyed goods constituting significant components

of the Company’s assets;

c) indication whether the subject goods have been insured;

d) other circumstances relating to the event in question that are important from the


9. Creation of significant intangible assets within the Company's assets, including in

particular: new licenses, patents, registered trademarks, the significance of

which is assessed by taking into account the projected costs and revenues from

their acquisition

If significant intangible assets are created within the Company’s assets, including in particular: new

licenses, patents, registered trademarks a report will be published that contains in particular the

following information:

a) description of factors which caused the creation of significant intangible assets within

the Company’s assets, including in particular: new licences, patents, registered

trademarks;

b) determination of the value of these assets, and their significance for the business

activity conducted by the Company;

c) position of the Company’s Management Board as to the impact of this event on the

future results of the Company or the Company’s Capital Group;



10. Significant reduction in the value of patents or rights or other intangible assets

In the event of a significant reduction in the value of patents or rights or other intangible assets of the

Company a report will be published that contains in particular the following information:

a) description of the factors that have caused the reduction in the value of patents,

rights or other intangible assets;

b) determination of the value of these assets after the change, and the significance of

that event for the business activity conducted by the Company;



11. Creation of significant innovative products or processes in the course of the

Company’s activities

If significant innovative products or processes are created in the course of the Company’s activities a

report will be published that contains in particular the following information:

a) description of the factors that caused the creation of significant innovative products

or processes in the course of the Company’s activities;

b) description of the innovative product or process and what that innovation consists

in;

c) determination of the significant innovative products or processes and the

significance of that event for the business activity conducted by the Company;



12. Significant decrease or increase in the value of financial instruments held by the

Company

In the event of a significant decrease or increase in the value of financial instruments held by the

Company a report will be published that contains in particular the following information:

a) determination of the carrying value of the financial instruments held by the

Company or its subsidiary, which are concerned by such a decrease or increase in

value;

b) determining the value of the decrease or increase in the value of financial

instruments held by the Company, and their value after such decrease or increase;

c) indication of the opinion of the Company's Management Board as to the reason for

the change in question;

d) position of the Company’s Management Board as to the impact of the event on the

Company's financial results and any potential risks associated with it;



13. Company's decision to withdraw from or enter into a new area of primary activity

If the Company decides to withdraw from or enter into a new area of primary activity, a report will be

published that contains in particular the following information:

a) presentation of the reasons why the Company decided to withdraw from or enter

into a new area, concerning primary activity;

b) determining the scale of the change associated with the subject decision;



14. Making a decision concerning a significant change in the Company’s investment

policy

If a decision is made concerning a significant change in the Company’s investment policy, a report will

be published that contains in particular the following information:

a) presentation of the reasons behind the Company’s decision to change its

investment policy;

b) determining the scale of the change associated with the subject decision;



15. Establishment of a mortgage, a pledge or other limited right in rem on the Material

Assets by the Company or by its subsidiary

If the Company or its subsidiary establishes a mortgage, a pledge or other limited right in rem on the

Material Assets a report will be published that contains in particular the following information:

a) designation of the entity on whose assets a mortgage, a pledge, or other limited

right in rem is established;

b) the date and manner of establishing such mortgage, pledge or other limited right

in rem;

c) information on the reasons for establishing such mortgage, pledge or other limited

right in rem;

d) basic characteristics of the assets on which a mortgage, a pledge, or other limited

right in rem is established;

e) the value of the obligation secured by that limited right in rem established and the

book value of those assets in the books of the Company or its subsidiary;

f) nature of relations between the Company and persons managing or supervising

the Company and the person for the benefit of whom the mortgage was

established, the pledgee and the person for whom other limited rights in rem were

established, and persons managing them;

g) the criterion for recognising that the given assets are Material Assets;

h) in case of encumbering shares (either in a joint-stock company or a limited liability

company) with a limited right in rem held in other entities - additionally:

− the name (business name) of the entity whose shares (either in a joint-stock

company or a limited liability company) are subject to a limited right in rem;

− their share in the share capital of this entity and the nominal value of these

assets

− their nature as a long-term or short-term capital investment of the Company

or its subsidiary,

− share of the Company or its subsidiary in the share capital and the number of

votes held at the general meeting of shareholders of the entity whose shares

(either in a joint-stock company or a limited liability company) were acquired

or disposed of;

i) if the agreement on the encumbering assets with the limited right in rem is an

agreement with a related entity – additionally, a description of the Company’s or

its subsidiary’s relations with the person to the benefit of whim that limited right

in rem was established, detailed description of the terms of that agreement;

j) other circumstances relating to the event in question that are important from the


16. Adoption of a new development strategy for the Company or the Company’s Capital

Group or introducing significant changes to the previously announced strategy

If a new development strategy is adopted for the Company or the Company's Capital Group, or if

significant changes are made to the previously announced strategy a report will be published that


a) date of adoption of the new strategy, or of its amendment, along with an indication

of the authorities of the company that have made decisions in this respect;

b) identification of the key elements of the strategy in question or its amendment,

together with the definition of its time frame;



17. Deciding to issue bonds where the value of the issued bonds exceeds the

Significance Threshold, and in the case of an issue of bonds convertible into

shares, bonds with pre-emptive right and revenue bonds

In the event of:

a) issue of bonds when the value of the issued bonds exceeds the Significance

Threshold,

b) issue of bonds convertible into shares, bonds with pre-emptive rights and revenue

bonds a report will be published that contains in particular the following

information:

a) purpose of the bond issue, if specified;

b) determination of the type of bonds to be issued;

c) the volume of the issue, indicating whether the issue is private or public;

d) nominal value and issue price of bonds or the manner of its

determination, the terms and conditions of issue, in particular those

relating to buy-back, interest rate and conditions of payment of interest

on such bonds;

e) amount and form of any security and the designation of the entity

providing the security;

f) if any form of pledge or mortgage is established as security for

receivables arising from the bonds - valuation of the object of the pledge

or mortgage by an authorised expert;

g) in the case of an issue of bonds convertible into shares - additionally:

• the adopted bonds to shares exchange ratio;

• number of votes at the general meeting of the Company that would be

attached to the shares if all issued bonds were converted;

• total number of votes at the general meeting of the Company - if all issued

bonds were converted;

h) in the case of an issue of bonds with pre-emptive right - the following

additional information is provided:

• number of shares per bond;

• issue price of the shares or the manner of its determination;

• dates from which the bondholders’ rights to acquire such shares are vested

and expire;

i) other elements of a given issue which are important for its assessment

from the viewpoint of investors, important from the viewpoint of the

Company.

18. Cancellation or liquidation of lines of credit by one or more banks if their value exceeds

the Significance Threshold

In the event of cancellation or liquidation of lines of credit by one or more banks concerning a

significant part of the current financing of the Company’s operations, a report will be published that


a) value of financing obtained by the Company from the lines of credit in question,

with an indication of the percentage share of these lines of credit in the total

financing held by the Company to date;

b) other circumstances relating to the event in question that are important from the


19. Making a decision to issue shares of the Company or other securities of the Company

If a decision is made about an intended issue of securities a report will be published that contains in


a) type and value of the planned issue of securities, with an indication of whether the

issue is a private issue or public issue;

b) planned date of the issue in question;

c) purposes of the planned issue of securities;

d) other circumstances and information important for the planned issue of securities

from the perspective of the Company's operations.

20. Purchase or sale by the Company of securities issued by the Company if the value of

such securities exceeds the Significance Threshold

If the Company or its subsidiary acquires or disposes of securities issued by the Company, a report will

be published that contains in particular the following information:

a) legal basis for the acquisition of the securities, with an indication of the purpose of

the acquisition;

b) number of securities acquired or disposed of;

c) reasons for and purpose of acquisition or disposal of securities;

d) average unit purchase or sale price of a security;

e) indication of the total number of the Company’s shares held and indication of the

number of votes at the General Meeting corresponding to the Company’s shares

held - in case the Company or its subsidiary purchases or sells its own shares;



21. Granting by the Company or its subsidiary for the benefit of one or more related entities

a surety for a loan or bank loan or granting a guarantee if the value of such surety or

guarantee exceeds the Significance Threshold

If the Company or its subsidiary grants a surety for a loan or bank loan or grants a guarantee a report

will be published that contains in particular the following information:

a) name (business name) of the entity to which the surety or guarantee is granted;

b) total amount of any bank loan, loan or other liability that is entirely or partly guaranteed

or secured by a guarantee, together with an indication of the amount of the surety or

guarantee provided by the Company;

c) period for which the surety or guarantee was granted;

d) financial terms on which the surety or guarantee was granted, specifying the

remuneration of the Company or its subsidiary for granting the surety or guarantee;

e) the nature of the links existing between the Company and the entity that took out the

loan or bank loan;



22. Initiation of proceedings before a court, arbitration authority or public administration

authority concerning liabilities or receivables of the Company or its subsidiary, if the

value of potential claims exceeds the Significance Threshold

In the event of initiation of proceedings before a court, arbitration authority or public administration

authority concerning liabilities or receivables of the Company or its subsidiary a report will be


a) subject matter of the proceedings;

b) amount in dispute;

c) date of initiation of the proceedings;

d) parties of the pending proceedings;

e) the Company's position;



23. Deciding on: intention to submit a petition for bankruptcy declaration or for initiation

of restructuring proceedings, submission of a petition for bankruptcy declaration;

dismissal of the petition for bankruptcy declaration, if the assets of the debtor are not

sufficient to satisfy the costs of the bankruptcy declaration; opening of restructuring

proceedings; acceptance of an arrangement in restructuring proceedings; conclusion or

discontinuation of bankruptcy or restructuring proceedings - in relation to the Company

or its subsidiary

In the matters related to insolvency or threat of insolvency of the Company a report will be published


a) in the case of a petition for bankruptcy declaration: indication of the court to which the

petition for bankruptcy declaration has been filed, the date on which the petition was filed

and the entity that filed the petition;

b) where the petition for bankruptcy declaration in the event that the debtor's assets are

insufficient to cover the costs of the proceedings or suffice only to cover such costs, or to

issue another ruling that ends the proceedings: indication of the court which has dismissed

the petition, the reasons for such a ruling and the date of its issue;

c) in case of bankruptcy declaration: indication of the court which declared the bankruptcy, the

date of the ruling, the judge-commissioner, the deputy judge-commissioner and the

receiver;

d) in the case of conclusion or discontinuance of insolvency proceedings - indication of the

nature of the decision, the court which issued the ruling, the reasons, the date of its issue;

e) in the case of a petition to initiate restructuring proceedings - indication of the court to which

the petition was submitted, the type of restructuring proceedings and the date of submission

of the petition;

f) in the case of securing the Company's assets in the proceedings to open the restructuring

proceedings: indication of the method of security imposed and the date of the ruling;

g) in the case of proceedings to approve the arrangement - indication of the supervisor of the

arrangement, the arrangement date, arrangement proposals, report of the supervisor of the

arrangement, information on the results of the creditors' vote, date of the Company's

petition to approve the arrangement, and then indication of the court’s decision on approval

of the arrangement;

h) in the case of accelerated arrangement proceedings or arrangement proceedings: indication

of the date of the petition to open the proceedings and arrangement proposals together

with a preliminary restructuring plan; in the case of a court decision to open the proceedings

- information about it together with the date of the decision and indication of the judge-

commissioner and court supervisor; in the case of a court supervisor's submission of the

restructuring plan - its contents; in the case of acceptance of the arrangement - information

about it, the date of the creditors' meeting and the contents of the arrangement; in the case

of a court decision to approve the arrangement - information about the type of the decision

together with the date of the court's ruling;

i) in the case of curative proceedings - indication of: the date of the petition to open the

proceedings and the preliminary restructuring plan; in the case of the court's decision to

open the proceedings - information about it together with the date of the decision and

indication of the judge-commissioner and the administrator; in the case of the

administrator's submission of the restructuring plan - its contents; in the case of approval of

the restructuring plan - information about it, the date of the judge-commissioner's decision;

in the case of acceptance of the arrangement - information about it, the date of the creditors'

meeting and the contents of the arrangement; in the case of the court's decision to approve

the arrangement - information about the type of decision together with the date of the

court's ruling;

j) in the event of conclusion or discontinuance of the restructuring proceedings, providing

information about it together with the date of the decision and indication of the ruling's

contents.

In each of the above cases, the Company must indicate in the submitted report containing the Inside

Information also other circumstances concerning the event in question which are of significance from

the viewpoint of the Company.

24. The Company’s acquisition of verified information on concluded agreements

concerning exercising or taking control over the Company

If the Company or its subsidiary acquires verified information on concluded agreements

concerning exercising or taking control over the Company a report will be published that contains in


g) the extent of the change of control, indicating the entity or entities which may acquire control or

are party to agreements to exercise or take control over the Company;

h) other circumstances relating to the event in question that are important from the viewpoint of

the Company.

25. Preparation of forecasts or estimates of the Company’s or the Company’s Capital

Group’s financial results, if the Company has decided to publish them and any

significant changes to the forecasts or estimates of the Company’s or the Company’s

Capital Group’s financial results published earlier

If a forecast or an estimate of the Company’s or the Company’s Capital Group’s financial results is

prepared, if the Company has decided to make them public, the Company will publish a report

containing in particular the following information:

a) forecast or estimated results;

b) period covered by the forecast;

c) basis and significant assumptions of the forecast;

d) manner in which the Company monitors the possibility of achieving the forecast results;

e) periods in which the Company will assess the feasibility of the forecast results and

possible adjustment of the presented forecast, together with specification of the

criteria used for such assessment;



The Company also immediately, in the form of a report, provides a correction of the forecast contained

in the previous report, if at least one of the forecast items differs significantly from the item contained

in the last published forecast, in accordance with the conditions set out in the Company’s Information

Policy.

A report containing an adjustment of the forecast submitted by the Company during a given financial

year must be considered a new forecast of the Company's results. A report containing an adjustment

of the forecast must include an indication of the item that is adjusted and the forecast results after

the adjustment, as well as the factors which affected the increase or decrease of the previously

published forecast.

If the forecast of the Company's or the Company’s Capital Group financial results has been reviewed

by a certified auditor, the Company attaches a report of the certified auditor to the forecast of financial

results to the said report.

26. Granting or changing the rating granted at the Company’s request

In the event of granting or changing the rating granted at the Company's request a report will be


a) name of the rating agency;

b) indication of the rating assigned, with a brief description;

c) in case of a change to the previously awarded rating, indication of the reasons for the

change of rating;



27. Learning about the insolvency of significant debtors of the Company

In the event of learning about the insolvency of significant debtors of the Company a report will be


a) identification of the entity or entities concerned by the above information;

b) determination of the value of liabilities which the debtors in question have towards the

Company, together with an indication of the share of such amounts in the Company's

annual revenue;



28. Materialisation of risks related to the Company’s operations, in particular

decisions concerning the creation and release of material reserves

In the event of materialisation of risks related to the Company's operations a report will be published


a) type of significant risk concerning the Company's operations and the circumstances of its

occurrence;

b) the assessment by the Management Board of the Company of the scope of

materialisation of the above mentioned risk, if it is possible at the time when the above

risk is confirmed;

c) titles and amounts of significant provisions created or released, reasons for their creation

or release, information whether it is a one-off event and the Management Board's

position on the impact of the created or released significant provisions on the current

and future financial results of the Company and the Company’s Capital Group;



29. Court registration of a change in the amount or structure of the Company’s share

capital

In the event of the court registration of a change in the amount or structure of the Company’s share

capital a report will be published that contains in particular the following information:

a) date of registration of the change in the amount or structure of the Company’s

share capital by the court;

b) the amount and, where applicable, the structure of the share capital after such

change registration;

c) total number of votes resulting from all issued shares (either in a joint-stock

company or a limited liability company), after the registration of the change in the

amount or structure of the share capital;



30. Change of rights from the Company’s securities

In the event of a change of rights from securities a report will be published that contains in particular

the following information:

a) indication of the Company's securities the rights from which were changed,

quoting their number;

b) indication of the legal basis for the actions taken, as well as the contents of the

resolutions of the relevant Company authorities, by virtue of which the rights from

the Company’s securities were changed;

c) full description of the rights attached to the securities before and after the change

- relating to these changes;

d) in case of conversion of registered preferred shares into bearer shares -

additionally:

− number of registered shares that were subjected to change;

− amount of the Company’s share capital and total number of votes at the

General Meeting after the change;

e) in the event of a change in the rights from preferred shares in a manner other than

by changing the number of votes that are carried by such shares - additionally:

− number of shares the rights from which were changed;

− determining changes in the rights from shares;

f) in the event that bearer’s shares are converted into registered preferred shares -

additionally:

− number of bearer’s shares that were converted;

− determination of the type of preference for the registered shares after the

conversion of bearer's shares into registered preferred shares;

− amount of the Company’s share capital and total number of votes at the

General Meeting after the change.



In the case of a bond issue, a change in the interest rate of the bonds is also considered a change in

the rights attached to securities.

For each conversion of convertible bonds into shares, whose total value exceeds 5% or a multiple of

5% of the value of the bonds convertible to shares originally issued by the Company, a report will be


a) date of submission by the Company of the notice on the increase in the share capital as a

result of converting bonds into shares;

b) number of shares to be issued in exchange for the bonds;

c) structure of the share capital after the conversion of bonds into shares, specifying the amount

of the Company's share capital and the number of votes at the General Meeting of

Shareholders as well as the share of new shares in the share capital and in the total number

of votes at the General Meeting of Shareholders;

d) number of bonds that have not been converted into shares;

e) other circumstances relating to the event in question that are important from the viewpoint

of the Company.

31. Cancellation of the Company's shares

In the event of cancellation of the Company's shares a report will be published that contains in


a) number of shares cancelled;

b) number of votes corresponding to the cancelled shares;

c) determination whether the cancellation took place with the shareholder's consent

(voluntary cancellation) or without the shareholder's consent (compulsory

cancellation), and if the compulsory cancellation took place as a result of a specific

event without a resolution of the general meeting

− description of the event;

d) amount of remuneration due to the shareholder of the cancelled shares or

justification for cancelling shares without remuneration;

e) amount of the Company’s share capital and total number of votes at the General

Meeting after the cancellation;



32. Decision to combine the Company with another entity

If a decision is made to combine [the Company] with another entity a report will be published that


a) reasons for the decision to combine and information on the long-term objectives

to be achieved as a result of the measures taken;

b) method of the planned combination (acquisition or formation of a new company)

with indication of its legal basis;

c) identification of the entities which are to be combined, together with the basic

characteristics of their activities;

d) combination plan, drawn up in accordance with Article 499 § 1 of the Code of

Commercial Companies and Partnerships, together with the attached documents

referred to in Article 499 § 2 of the Code of Commercial Companies and

Partnerships;

e) Management Board’s report, prepared pursuant to Article 501 of the Code of

Commercial Companies and Partnerships;

f) a written opinion of an expert, drawn up in line with Article 503 § 1 of the Code

of Commercial Companies and Partnerships;



33. Combination of the Company with another entity

If the Company is combined with another entity a report will be published that contains in particular


a) method of the combination (acquisition or formation of a new company) with

indication of its legal basis;

b) identification of the entities which have been combined, together with the basic


c) date of entry of the combination into the register competent for the seat of the

acquiring company or the newly established company, respectively (combination

date);



34. Making a decision on the division of the Company and performing the division of the

Company

If the decision is made to divide the Company a report will be published that contains in particular


a) reasons for the decision to combine and information on the long-term objectives

to be achieved as a result of the measures taken;

b) method of the planned combination (acquisition or formation of a new company)

with indication of its legal basis;



d) division plan, drawn up in accordance with Article 534 § 1 of the Code of

Commercial Companies and Partnerships, together with the attached documents

referred to in Article 534 § 2 of the Code of Commercial Companies and

Partnerships;

e) written Management Board’s report, prepared pursuant to Article 536 of the Code

of Commercial Companies and Partnerships;

f) written expert opinion drawn up in accordance with Article 538 § 1 of the Code of

Commercial Companies and Partnerships or information that the requirement to

draw up a statement referred to in Article 534 § 2(4) of the Code if Commercial

Companies and Partnerships was waived, as well as the requirement to have the

division plan examined and an opinion of an expert drawn up;



In the event of the Company’s division a report will be published that contains in particular the


a) method of division (by takeover, by incorporation, by acquisition and incorporation

or by spin-off) with an indication of the legal basis;

b) identification of the entities which were created after the division, together with

the basic characteristics of their activities;

c) date of entry of the newly formed company in the relevant register;

d) date of entry of the resolution on division into the relevant register;

e) date of deletion of the company being divided from the register (date of division);



35. Making a decision to transform the Company and transforming the Company

If the decision is made to transform the Company a report will be published that contains in particular


a) reasons for the decision to combine and information on the long-term

objectives to be achieved as a result of the measures taken;

b) method of the planned combination (acquisition or formation of a new

company) with indication of its legal basis;



d) transformation plan, drawn up in accordance with Article 558 § 1 of the Code

of Commercial Companies and Partnerships, together with the attached

documents referred to in Article 558 § 2 of the Code of Commercial Companies

and Partnerships;

e) written opinion of a certified auditor, drawn up in line with Article 559 § 4 of

the Code of Commercial Companies and Partnerships;

f) resolution on transformation, adopted in accordance with Article 562 of the

Code of Commercial Companies and Partnerships;

g) other circumstances relating to the event in question that are important from

the viewpoint of the Company.

In the event of the Company’s transformation a report will be published that contains in particular the


a) determination of the legal basis for the decision to transform;

b) determination of the mode and conditions of the transformation, in

particular:

− indication of the type of a company into which the Company was transformed;

− estimated value of the Company's equity as at the date of transformation;

− estimated value of equity of the transformed entity and the method of

covering the share capital;

c) articles of association or incorporation of the transformed entity;

d) date of entry of the transformed company in the register and deletion from

the register of the company being transformed (date of transformation);

e) other circumstances relating to the event in question that are important

from the viewpoint of the Company.

36. Selection by a competent authority of the Company of an entity authorised to

audit financial statements with whom an agreement on reviewing or auditing is

to be concluded, and termination by the Company or by such entity authorised

to audit financial statements of such an agreement on reviewing or auditing, as

well as termination of such an agreement by mutual consent

If a competent authority of the Company selects an entity authorised to audit financial statements,

with whom an agreement on reviewing or auditing is to be concluded, a report containing in particular

the following information shall be submitted to the market:

a) details of the entity authorised to audit financial statements, selected by the

relevant authority of the Company with whom an agreement on reviewing or

auditing is to be concluded, stating:

− name (business name), seat and address;

− basis for the entitlements;

b) date of selection of the entity authorised to audit financial statements;

c) determining whether the Company used the services of a selected entity

authorised to audit financial statements, and if so, to what extent;

d) identification of the authority which has selected the entity authorised to audit

financial statements, together with an indication that it has been performed in

accordance with applicable regulations and professional standards;

e) indication of the period for which the agreement is to be concluded;



If the Company or the entity authorised to audit financial statements terminates the agreement on

reviewing or auditing and if such an agreement is terminated by mutual consent, a report will be


a) indication whether the termination of the agreement results from a decision of the

entity authorised to audit financial statements or from a decision of the Company;

b) indication of cases where expressing an opinion, issuing negative opinion or opinion

with reservations as to the accuracy and reliability of financial statements or the

consolidated financial statements of the Company was waived;

c) identification of authorities recommending or approving of the change of the entity

authorised to audit financial statements;

d) description of discrepancies in the interpretation and application of legal regulations

or provisions of the articles of association concerning the subject and scope of the

audit or review, which took place between the managing persons and the certified

auditor who conducted the audit or review during the term of the agreement which

is subject to termination, with an indication of the method of resolving them;



The Company will attach to the subject report or provide immediately after obtaining it the letter of

the certified auditor drawn up on request of the Company and addressed to the supervising authority,

in which they confirm the information provided in the subject report or refuse to confirm them.

37. Dismissal or resignation of the managing or supervising person or the Company

becoming aware of the decision of the managing or supervising person to resign

from applying for election in the next term

In the event of dismissal or resignation of the managing or supervising person or the Company

becoming aware of the decision of the managing or supervising person to resign from applying for

election in the next term a report will be published that contains in particular the following

information:

a) date of dismissal or resignation of the managing or supervising person or the date

of the Company becoming aware of the decision of the managing or supervising

person to resign from applying for election in the next term;

b) name of the managing or supervising person;

c) function held to date within the Company's enterprise;

d) reasons for dismissal or resignation, if these reasons are given by the authority or

person making the decision;



38. Appointment of a managing or supervising person in the Company

If the decision is made to appoint a managing or supervising person a report will be published that


a) date of appointment of the managing or supervising person;

b) name of the appointed managing or supervising person;

c) indication of the function entrusted within the Company;

d) education, qualifications and previous positions, together with a description of

professional career;

e) indication of other activities performed outside the Company's enterprise, with

an assessment of whether they are in relation to the activities performed in the

enterprise of a competitive company and indication of whether this person

participates in a competitive company as a partner in a civil-code partnership, a

registered partnership or as a member of an authority within a company, or

participates in another competitive legal person as a member of its authority;

f) information on the entry of an appointed managing person or supervising person

in the Register of Insolvent Debtors maintained pursuant to the Act on the

National Court Register;



39. Completion of subscription or sale procedure related to the introduction of

securities of the Company into trading

In the case of completion of the subscription or sale related to the introduction of the Company's

securities to trading on the official stock exchange market and allocation of the Company's securities


a) start and end date of the subscription or sale;

b) date of allocation of the securities;

c) number of securities covered by subscription or sale;

d) number of securities which were allocated in the subscription or sale;

e) price at which securities were purchased (subscribed for);

f) number of persons to whom securities were allocated in the subscription or sale

in individual tranches;

g) value of the subscription or sale, understood as the product of the number of

securities offered and the issue or sale price;

h) other circumstances relating to the event in question that are important from the


40. Admission or refusal to admit the Company’s securities to trading

In the case of admission of the Company’s securities to trading on the official stock exchange market


a) admission of the Company’s securities to trading on the official stock exchange

market with the specification of the date of admission, number of admitted

securities and their series;

b) setting the date of the first listing of the Company's securities in circulation on

the official stock exchange market;

c) determining the date of the first listing of securities after assimilation of the

Company’s securities, introduced to trading on the official stock exchange

market, with the Company’s securities already traded on that market;



In the case of a refusal to admit the Company’s securities to trading on the official stock exchange

market a report will be published that contains in particular the following information:

a) refusal to admit the Company's securities to trading on the official stock exchange

market with the date of such refusal and indication of the reasons for such refusal,

if any,

b) number of securities not admitted and their series,



41. Being listed on the territory of a country which is not a Member State of the

European Union

In the case of any listing the Company's securities within the territory of a country which is not a

member state, a report will be published that contains in particular the information disclosed in

accordance with the regulations in force on the market on which its securities are listed, provided that

the scope of such information is wider than the scope of information provided on the basis of the

adopted reporting standards, as well as other circumstances concerning the event in question which

are important from the Company's point of view.

The information referred to above should be provided simultaneously with their transfer to the

market where the Company's securities are listed.

In the case of listing the Company's securities within the territory of a non-Member State, the

Company must additionally provide, in the form of a separate report, information on the

commencement and completion of proceedings related to the Company's fulfilment of information

obligations, conducted by the authorities supervising the market on which the Company's securities

are issued and traded, together with the specification of the scope of such proceedings and the

decision made in the case in question.

42. Information on convening and holding of the General Meeting of the Company

In the case of events concerning the course of the Company's general meeting of shareholders, reports

will be published that contain in particular the following information:

a) in the case of an intended or performed change in the articles of association - the

provisions of the articles that are currently in force, the contents of the proposed

or performed changes and:

b) if, due to a significant scope of the intended changes, the Company decided to draft

a new consolidated text of the articles of association together with a list of new or

amended provisions of the articles of association,

c) if the Company has drawn up the consolidated text of the articles of association

taking into account changes thereto - the content of the consolidated text of the

articles of association;

d) content of draft resolutions and attachments to these drafts;

e) if the agenda of the general meeting is amended at the request of a shareholder

or shareholders - a new agenda with a list of new or amended items and the

content of draft resolutions or with a justification for the new or amended items;

f) if a shareholder or shareholders submit(s) draft resolutions concerning matters

included in the agenda of the general meeting or matters which are to be included

in the agenda of the general meeting - the content of draft resolutions;

g) information on the announcement of an adjournment of the general meeting,

together with the date and place of its resumption;

h) content of resolutions adopted by the general meeting and the content of

attachments to these resolutions, and for each resolution also the number of

shares from which valid votes were cast and the percentage share of these shares

in the share capital, the total number of valid votes, including the number of votes

cast "for", "against" and "abstaining votes";

i) information on the general meeting's decision not to consider any of the items on

the planned agenda;

j) information on objections raised to be recorded in the minutes during the general

meeting, indicating which resolutions they concerned;

k) information about bringing an action for annulment or invalidation of a resolution

of the general meeting and about the court's judgement in the case, as well as

about the date of the annulment or revocation of the resolution or dismissal of the

action;

l) all decisions concerning declarations of payments or withholding of advance

payments of anticipated dividends and payments or withholding of dividends or

interest on securities;

m) information provided to a shareholder outside the general meeting of shareholders

pursuant to Article 428 § 5 or 6 of the Code of Commercial Companies and

Partnerships;

n) granted to a shareholder, pursuant to Article 429 § 1 of the Code of Commercial

Companies and Partnerships, information resulting from the obligation imposed by

the registration court on the Company's Management Board to grant to a

shareholder who raised an objection to be recorded in the minutes as regards the

refusal to disclose information requested at the general meeting, and information

which the Company was obliged to announce, pursuant to Article 429 § 2 of the

Code of Commercial Companies and Partnerships, by the registration court, and

which was granted to another shareholder outside the general meeting;

o) if the general meeting passes a resolution to pay the dividend, the Company must

provide, in the form of Inside Information, information on the amount of the

dividend, the value of the dividend per share, the number of shares covered by the

dividend, the dividend date and the dividend payment date;

p) in the case of a general meeting at which a resolution is planned to be adopted to

increase the Company's share capital from the Company’s funds, if the last financial

statements fall on the balance sheet date at least six months before the date of

the general meeting, the Company must provide, in the form of Inside Information,

the information specified in Article 442 § 2 of the Code of Commercial Companies

and Partnerships, which should be presented at that meeting.

In each of the above cases, the Company will also indicate in the report

other circumstances relating to the event in question that are important from the viewpoint of the

Company.

43. Decisions concerning the share buy-back programmes or transactions on other listed

financial instruments

In the case of planned decisions concerning share buy-back programmes or transactions on other

listed financial instruments a report will be published that contains in particular the following

information:

In case of buy-back of own shares:

a) total number and type of own shares covered by the programme;

b) percentage share of the said own shares in the share capital, and in the total number of votes

attached to all the Company's shares;

c) reasons for the planned decision in this regard concerning own shares;

d) objectives that are planned to be achieved;

e) planned date and manner of conducting the buy-back of own shares, together with an

indication of the method of financing the buy-back;

f) other circumstances relating to the event in question that are important from the viewpoint

of the Company.

In case of transactions on other listed financial instruments:

a) number and type of financial instruments concerned by this decision;

b) value of the planned transaction, if identifiable;

c) reasons for the planned transaction in this regard concerning financial instruments;

d) objectives to be achieved and the risks associated with the planned transaction;

e) other circumstances relating to the event in question that are important from the viewpoint

of the Company.

44. Adoption of the Company’s dividend policy or amendments thereto, if such dividend

policy has been adopted earlier

If the Company adopts a dividend policy or changes thereto, if such dividend policy has been adopted

earlier a report will be published that contains in particular the following information:

a) the date of adoption or amendment of the dividend policy, together with an

indication of the authority which approved the policy or amendment;

b) the main assumptions behind the subject policy or an amendment to it;

c) reasons for adopting or amending this policy;

d) expected effects of adopting or amending the policy;



Final provisions

1. This Information Policy is introduced by a resolution of the Management Board of the Company.

2. The Company will periodically verify the validity of the Information Policy, in particular with

regard to changes in the applicable laws and the phenomena and events occurring within the

Company.

3. Any changes to this Information Policy may be introduced only by way of a resolution of the

Management Board. The Company will make any modifications to this Information Policy public.

OF SUMMA LINGUAE TECHNOLOGIES SPÓŁKA AKCYJNA WITH … · Kommunicera AS based in Lingtech A/S...

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Transcript of OF SUMMA LINGUAE TECHNOLOGIES SPÓŁKA AKCYJNA WITH … · Kommunicera AS based in Lingtech A/S...