PROCEDURE AND DEADLINE FOR SUBMISSION OF NOTIFICATIONS – COMPETENT AUTHORITIES

Persons obliged to notify, in accordance with Articles 9, 10, and 11 of Law 3556/2007, must disclose significant changes in their holdings of voting rights in the Company simultaneously to the Company and the Hellenic Capital Market Commission (HCMC), as soon as possible and, in any case, no later than three (3) trading days following the date on which the shareholder or other person subject to notification obligations under Article 10:

• becomes aware of the acquisition or disposal or the ability to exercise voting rights, or
• should, taking into account the circumstances, have become aware of such acquisition, disposal, or ability to exercise voting rights, irrespective of the actual date on which the acquisition or disposal took place or the exercise of voting rights became possible, or
• is informed of an event referred to in paragraph 3 of Article 9 of the Law (corporate events). To facilitate the calculation of trading days, the Hellenic Capital Market Commission publishes on its website (www.hcmc.gr) the trading day calendars of organized markets operating in Greece. To the extent that the above information may be considered inside information, the persons subject to notification obligations must exercise due care in monitoring the execution of their trading orders and take all necessary measures to ensure timely notification. According to Article 14 of Law 3556/2007, the notification to the Company and to the HCMC shall include the following information:
• the resulting percentage of voting rights held after the acquisition or disposal,
• the chain of controlled undertakings through which the voting rights are effectively held, if applicable,
• the date on which the percentage of voting rights reached, exceeded, or fell below the thresholds set out above, and
• the identity of the shareholder, even if he/she is not entitled to exercise voting rights pursuant to Article 10 of the Law, as well as of the person entitled to exercise the voting rights on behalf of that shareholder.

The simultaneous notification to both the Company and the HCMC is made by submitting the relevant Notification Form, the template of which is available on the HCMC website (www.hcmc.gr) in both Greek and English. The form is accompanied by an Annex, to be completed by the persons subject to notification with their personal details and submitted only to the HCMC. When completing the Annex, it is recommended that the father’s name of the person concerned also be included. Please note that correct completion of the notification form is the responsibility of the notifying person, who is liable for any errors or omissions. Furthermore, the notification form must be duly signed before submission to both the Company and the HCMC. A notification is considered duly signed when it bears the signature of the person subject to notification or of another person duly authorized. If the person subject to notification is a legal entity, the notification must be signed by its legal representative. In all cases, supporting documentation evidencing the authorization must be submitted to both the Company and the HCMC, and shall remain valid until revoked. The duly signed notification form shall be submitted:

• To the Company: at its offices at 12th km of Athens-Lamia Nat. Road, Metamorfosi 14452 , to the Shareholders and Corporate Announcements Department (tel. +30 210 8029409), during working days and hours, marked “Notification of significant changes in voting rights pursuant to Law 3556/2007.” For shareholders’ convenience, the form may also be sent via email to alag@qnr.com.gr.
• To the Hellenic Capital Market Commission: duly signed and submitted to the HCMC Central Protocol Office (1 Kolokotroni & Stadiou St., 105 62 Athens), Directorate of Listed Companies – Continuous Information Department, marked “Notification of significant changes in voting rights pursuant to Law 3556/2007, as in force.”

The form may also be submitted via fax (+30 210 3377243) or by email to tr1@cmc.gov.gr. In all cases, the form must be properly completed and accompanied by a cover sheet including at least the sender’s details, signature, contact number, and the number of attached pages. The notifying person is responsible for ensuring successful delivery and receipt by the competent protocol service. The Hellenic Capital Market Commission is the competent authority for the supervision of the notification obligations. SANCTIONS Pursuant to Article 26 of Law 3556/2007, in the event of violations of the provisions of the Law or the decisions issued under it, the Hellenic Capital Market Commission may impose, indicatively:

• a reprimand or a fine up to €1,000,000,
• administrative measures and sanctions, such as a public statement naming the responsible natural or legal person and describing the nature of the infringement,
• for legal persons: a fine of up to €10,000,000 or 5% of total annual turnover, or up to twice the amount of the profits gained or losses avoided due to the infringement,
• for natural persons:
  • a fine of up to €2,000,000 or up to twice the amount of the profits gained or losses avoided due to the infringement,
  • suspension of the exercise of voting rights.

For further information, shareholders may contact the Company during business hours (tel. +30 210 8029409) or visit the Hellenic Capital Market Commission’s website at www.hcmc.gr, where the Law, the relevant Decisions, and Circulars are available.