Publication Procedure

Publication Procedure of Significant Holdings L.3556/2007 - 27/01/2022

LAMDA Development S.A. (the “Company”), in order to inform and facilitate its shareholders, provides hereby information regarding the obligation and the publication procedure of significant holdings, in accordance with the provisions of Law 3556/2007 (the “Law”), Decision Νο 1/434/03.07.2007 issued by the Board of Directors of the Hellenic Capital Market Commission (the “Decision”) as amended by Decision No. 12/754 / 14.04.2016 and in force, as well as the clarifications provided by the Guidance Circular 33/03.07.2007 issued of the Hellenic Capital Market Commission (the “Circular”).

OBLIGORS – PUBLICATION OF SIGNIFICANT HOLDINGS

According to articles 9, 10 and 11 paragraph 2 of the Law, Obliged persons for the notification of changes of significant holdings are the following:

• Every shareholder of the Company,
  • who acquires or holds shares of the Company with voting rights, and whose percentage of voting rights, due to this purchase / disposal, reaches, exceeds, or falls below the thresholds of 5%, 10%, 15%, 20%, 25%, 1/3, 50% and 2/3,
  • whose percentage of voting rights in the Company reaches, exceeds, or falls below the thresholds of 5%, 10%, 15%, 20%, 25%, 1/3, 50% and 2/3, because of corporate events which change the distribution of voting rights, regardless of whether there is an acquisition or disposal of shares of the Company,
  • who holds a percentage of voting rights over 10%, whenever there is a change in its percentage equal to or greater than 3% of the total voting rights in the Company, because of the purchase or the sale of the Company’s shares with voting rights or due to corporate events,
• Any individual or legal entity who is entitled to acquire, possess, or exercise voting rights in the Company directly or through a third party, when the percentage of voting rights that he is entitled to acquire, possess, or exercise, reaches, exceeds or falls below the thresholds 5 %, 10%, 15%, 20%, 25%, 1/3, 50% and 2/3 or has a change equal to or greater than 3%,
• Any individual or legal entity that acquires or possess, directly or indirectly through a third party, financial instruments, according to the conditions of paragraph 1 of article 11 of the Law.

The aforementioned obligors have an individual obligation to notify the above events to the Company and to the Hellenic Capital Market Commission, in accordance with article 14 of the Law.
The Company, in accordance with article 9 paragraph 5 of the Law and in order for the above persons to calculate the aforementioned thresholds, has published, the total number of voting rights and its paid up share capital in its announcement dated 23.12.2019, which has been posted on the Company’s website (www.lamdadev.com) as well as at the Athens Exchange website (www.athexgroup.gr).

PROCEDURE AND TIME FOR SUBMITTING THE NOTIFICATION – COMPETENT AUTHORITIES

The aforementioned obligors for notification, in accordance with articles 9, 10 and 11 of the Law, must notify any significant change of their holding in the voting rights of the Company, in accordance with the above provisions simultaneously to the Company and the Hellenic Capital Market Commission as soon as possible and in any case, the latest within three (3) trading days, after the date on which the obligor according to article 10:

1. is informed of the acquisition or the disposal or the right to exercise the voting rights, or
2. considering the circumstances each time, the obligor should have been informed of the acquisition or the disposal or the right to exercise the voting rights, irrespective of the date on which the actual acquisition or disposal or the right to exercise the voting rights took place, or
3. is informed of an event mentioned in article 9 paragraph 3 of the Law (company events).

To facilitate the counting of the trading days, the Hellenic Capital Market Commission publishes on its website (www.hcmc.gr) the trading days-calendar of regulated markets that are located or operate in Greece.

To the extent that the above information may be considered as privileged, the obligor must act with the required diligence in monitoring the orders given for the execution of the transactions and take the necessary measures, to be informed in due time whether they were executed or not and accordingly to proceed with their notification.

In accordance with article 14 of the Law, the notification to the Company and to the Hellenic Capital Market Commission should include the following information:

1. the percentage of voting rights held pursuant to the acquisition or the disposal,
2. the chain of the controlled companies through which the voting rights are essentially held, as the case may be,
3. the date on which the percentage of the voting rights reached, exceeded or went below the aforementioned thresholds, and
4. the identity of the shareholder, even if such shareholder does not have the right to exercise the voting rights in accordance with article 10 of the Law, as well as the identity of the person which is entitled to exercise the voting rights on behalf of the said shareholder.

The simultaneous notification to the Company and to the Hellenic Capital Market Commission is made by submitting to both the respective Notification Form, a template of which can be found on the Hellenic Capital Market Commission website (www.hcmc.gr) both in English and in Greek. The Annex attached to the template, is to be filled in by the obligors with their personal details and to be submitted only to the Hellenic Capital Market Commission. When filling in the Annex, it is recommended that, in addition to what is already mentioned there, the obligor mention his/her father’s name. It is noted that the obligor is liable for the accuracy of the notification and for any mistakes or omissions in it.

Furthermore, it is noted that the notification form must be submitted to the Company and to the Hellenic Capital Market Commission dully executed (signed). The notification form is dully signed when bearing the signature of the obligor or of any other person, legally authorized. In case the obligor is a legal entity, the notification form is signed by its legal representative. In any case, along with the notification form the respective authorization documents must be also submitted to the Company and to the Hellenic Capital Market Commission. Such documents remain in force until they are revoked.

The dully signed Notification Form is submitted:

1. to the Company, at its offices (37Α Kifissias Ave, post code 15123, Maroussi, Greece) to the attention of Investors Relation Department (telephone number + 30 210 7450600), during working days and hours, bearing the note «Notification of significant change in voting rights in accordance with the Law 3556/2007». To facilitate the shareholders, the notification form can be sent via email: [email protected]
2. to be submitted, legally signed, to the Protocol Dept. of the Hellenic Capital Market Commission (1 Kolokotroni and Stadiou Str., 105 62 Athens, Greece), c/o Directorate of Listed Companies, Dept. of Continuous Information, indicating «Form of Notification of Major Holdings». The legally signed form can also be sent either to the fax No.: +30-210-33.77.243 or to the e-mail address: [email protected]

In any case, the competent authority for supervising the notification obligations is the Hellenic Capital Market Commission.

SANCTIONS

It is noted that, according to article 26 of the Law, in case the provisions of the Law and the decisions issued upon the Law’s authorization are violated, the Hellenic Capital Market Commission can indicatively

• address a reproach or impose a fine up to €1,000,000.
• impose administrative measures and administrative sanctions, such as a public statement stating the culprit individual or legal entity and the nature of the infringement,
• for legal entities: impose a fine of up to ten million euros (€10,000,000) or up to 5% of the total annual turnover, or up to twice the number of profits earned or losses avoided due to the breach.
• for individuals: impose a fine of up to two million euros (€2,000,000) or up to twice the number of profits gained or losses avoided due to the infringement
• suspend the exercise of voting rights.

For further information, the Company’s shareholders may contact the Company during working days and hours at the telephone number + 30 210 7450600 or may consult the Hellenic Capital Market Commission’s website (www.hcmc.gr) where the Law, the Decision and the Circular are posted.