Shareholders' Rights

Minority Rights

Following a relevant application submitted by a Shareholder to the Company within at least 5 full calendar days prior to the General Meeting, the Board of Directors shall be obliged to provide the General Meeting with the requested specific information on the Company’s affairs, to the extent that such knowledge is useful for the actual assessment of the items of the daily agenda. Furthermore, it should be noted that there is no such requirement for disclosure of information if the relevant elements and info are already presented in the Company’s website, especially in the form of Q&A questions. The Board of Directors may refuse to provide the above information on a serious, substantive ground which shall be cited in the BoD minutes. Such reasoning may be relating, under the circumstances, to the representation of the applicant shareholder in the Board of Directors according to the articles 79 or 80 of Law 4548/2018. The Board of Directors may provide an answer on a uniform manner to the applications of shareholders with the same content. Any objection regarding the validity or not of such a refusal to provide information will be resolved by the Single-Member Court of First Instance located at the area of the Company’s seat and according to its relevant decision issued at the time of the injunctive relief procedure (injunction process). Under the same decision, the Court forces the Company to provide the relevant information which the Company initially declined. The particular court decision cannot be appealed by any legal means.

At the request of Shareholders representing 1/20 of the paid-up share capital:

• The Board of Directors shall be obliged to call for and then convene an Extraordinary General Meeting within a time period of forty five (45) days from the date a relevant request was presented to the Chairman of the Board of Directors. This application must contain the items of the agenda of the requested Meeting. If the General Meeting does not convene within twenty (20) days from the presentation of the request towards the Board of Directors, then the relevant convocation is performed by the applicant shareholders at the Company’s expense and according to a decision by the Single-Member Court of First Instance located at the area of the Company’s seat. The particular decision is issued along the injunction process. Moreover, the decision states the place and the time of the meeting as well as the daily agenda. The particular court decision cannot be appealed by any legal means.

• The Board of Directors shall be obliged to include additional items in the agenda of the General Shareholders’ Meeting that has been already convened, provided that it receives the relevant request within at least fifteen (15) days prior to the General Meeting. The additional items shall be published or notified by the Board of Directors at least seven (7) days prior to the General Meeting. The relevant request with regard to the additional items of the agenda shall be accompanied by the respective reasons necessitating such an inclusion or a draft decision for approval by the General Meeting whereas the revised agenda shall be published in the same manner as the previous one, meaning thirteen (13 days) before the date of the General Meeting. At the same time, the revised agenda shall be also made available to the shareholders through the Company’s website, along with its reasoning or the draft decision submitted by the shareholders. If these items are not released, the applicant shareholders are entitled to request the adjournment of the General Meeting according to the paragraph D’. At the same time, the applicant shareholders can proceed into the above release according to the provisions of the second section of the present paragraph at the Company’s expense.

• The above shareholders representing the one twentieth (1/20) of the paid up share capital have the right to submit decision drafts on the items which are included in the initial or the revised daily agenda of the General Meeting. The relevant request must be presented to the Board of Directors at least seven (7) days before the date of the General Meeting. At the same time, the decision drafts are made available to the shareholders according to the provisions of paragraph 3 of article 123 at least six (6) days prior to the date of the General Meeting.It is noted that the Board of Directors is not obliged to proceed with the inclusion of items in the daily agenda or to proceed with the release or disclosure of these along with their justification as well as the decision drafts presented by the shareholders according to the above two paragraphs, if the content of these items is clearly in conflict with the relevant law and market moral standards.

• The Chairman of the General Meeting shall be obliged to postpone only once the decision making process by the General Meeting, either ordinary or extraordinary one, and with regard to the entire or particular items, setting as the date for the continuation of the meeting the date stipulated in the request of shareholders. The particular date cannot be set later than twenty (20) days from the date of postponement. A postponed General Meeting which reconvenes shall be deemed a continuation of the previous meeting and as a result there will be no publication requirement concerning the invitation towards the shareholders anew. Provided that the relevant procedures concerning their participation in the meeting are fully observed, new shareholders are also entitled to participate in the particular Meeting as per above.

• The Board of Directors shall be obliged to announce to the Ordinary General Meeting the amounts that have been paid over the past two years to each member of the Board of Directors or the Company’s directors, as well as any benefits granted to these persons due to any reason or contractual agreement concluded between these persons and the Company. Towards the above purpose, a relevant application is submitted at five (5) full days prior to the Ordinary General Meeting. The Board of Directors may refuse to provide such information on a serious and substantive ground which shall be cited in the minutes. Such reasons may relate, under the circumstances, to the representation of the applicant shareholders in the Board of Directors according to the articles 79 or 80 of Law 4548/2018. Any objection regarding the validity or not of such a refusal to provide information will be resolved by a court decision released along the injunction process. Via the same decision, the court will be forcing the Company to provide the relevant information and elements which the Company initially declined. The particular court decision cannot be appealed by any legal means.

• Voting on any item of the daily agenda of the General Meeting is conducted through an open voting.

• In addition, shareholders representing the one tenth (1/10) of the paid-up share capital are entitled to request an audit of the company by the court which is ruling on the case according to the procedure of voluntary jurisdiction as it is stipulated by the article 142 of Law 4548/2018. In any event, the request for an audit must be submitted within three (3) years from the approval of the financial statements of the fiscal year during which the transactions under doubt took place.