INSIDERADMINISTRATION

Multitude complies with the Market Abuse Regulation ((EU) N:o 596/2014, “MAR”) and its implementing instruments, the Prevention of Financial Markets Abuse Act (Chapter 476 of the Laws of Malta), the German Securities Trading Act, as amended (Wertpapierhandelsgesetz – WpHG) as well as the regulations and guidelines of ESMA (European Securities and Markets Authority), the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht) and the Malta Financial Services Authority. In addition, Multitude complies with the listing rules and regulations of the regulated market of the Frankfurt Stock Exchange and the additional requirements of the Prime Standard of the Frankfurt Stock Exchange.

Lea Liigus is responsible for the coordination and supervision of insider issues.

Insiders at Multitude

Multitude maintains non-public project-based insider lists of all persons who have access to deal-specific or event-based inside information and who are working for them under a contract of employment, or otherwise performing tasks through which they have access to inside information. In addition, Multitude maintains a non-public insider list of the permanent insiders of Multitude. Such insiders consist of members of the Board of Directors, the CEO and members of the Leadership Team of Multitude (“Managers”).

Closed period

Multitude applies a closed period of 30 calendar days before the announcement of interim financial reports or financial statements and ending upon the publication of such announcement. During the closed period, Multitude’s Managers are prohibited from trading in Multitude’s financial instruments. Multitude has imposed a 30-days closed period preceding the announcement of interim financial reports and financial statements also on persons involved in the preparation of such reports or statements.

Management holdings in Multitude