KIRIACOULIS MEDITERRANEAN CRUISES SHIPPING S.A. (the “Company”) for the purpose of informing and facilitating its shareholders, discloses information relating to the obligation and procedure for disclosure of major holdings in accordance with the provisions of Law 3556/2007 (hereinafter the “Law”), Decision No. 1/434/03.07.2007 of the Board of Directors of the Hellenic Capital Market Commission, (hereinafter “the Decision”), as amended by Decision No. 12/754/14.4.2016 and applies, as well as the clarifications of the interpretative circular 33/03.07.2007 of the Hellenic Capital Market Commission (hereinafter referred to as “the Circular”).

OBLIGATED PERSONS – DISCLOSURE OF MAJOR HOLDINGS

According to articles 9, 10 and 11 of the Law, persons obliged to notify changes in major holdings are the following:

• Every shareholder of the Company,
• in case it acquires or disposes of shares of the Company with voting rights, and of which, due to this acquisition/disposal, the percentage of voting rights they hold, reaches, exceeds or falls below the thresholds of 5%, 10%, 15%, 20%, 25%, 1/3, 50% and 2/3,
• in case their 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, as a result of corporate events that alter the distribution of voting rights, regardless of whether there is an acquisition or disposal of shares of the Company,
• in case they hold more than 10% of voting rights, whenever there is a change in their percentage equal to or greater than 3% of the total voting rights in the Company, as a result of the acquisition or disposal of shares of the Company with voting rights or due to corporate events,
• Any natural or legal person entitled to acquire, dispose of or exercise voting rights in the Company directly or through a third party, when the percentage of voting rights entitled to acquire, dispose of or exercise, reaches, exceeds or falls below the thresholds of 5%, 10%, 15%, 20%, 25%, 1/3, 50% and 2/3 or makes a change equal to or greater than 3%,
• Any natural or legal person who acquires or disposes, directly or indirectly through a third party, financial instruments, provided that the conditions of paragraph 1 of article 11 of the Law are met.

The above obliged persons must notify the above to the Company and 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, for the calculation of the above limits, published on 21.07.2023 the total number of voting rights and its share capital with an announcement, which is posted on the Company’s website (www.kiriacoulis.com) and that of the Athens Exchange (www.athexgroup.gr).

PROCEDURE AND TIME FOR SUBMITTING A NOTIFICATION – COMPETENT SERVICES

The persons charged with the obligation to inform, in accordance with articles 9, 10 and 11 of the Law, must notify significant changes, in accordance with the above provisions, to their participations in the Company’s voting rights simultaneously to itself (the Company) and the Hellenic Capital Market Commission as soon as possible and in any case, no later than three (3) trading days after the date on which the shareholder or the obligated person referred to in Article 10:

• has been informed of the acquisition or disposal or of the possibility of exercising voting rights, or, taking into account the circumstances of the case, should have been informed of the acquisition or disposal or of the possibility of exercising voting rights, irrespective of the date on which the acquisition or disposal takes place or the exercise of voting rights becomes possible, or
• is informed about an event referred to in paragraph 3 of Article 9 of the Law (corporate events).

For the purpose of facilitating the monitoring of trading days, the Hellenic Capital Market Commission publishes on its website (www.hcmc.gr) the trading day calendars of regulated markets located or operating in Greece.

To the extent that the above information can be considered confidential, obliged persons must exercise the necessary diligence in monitoring the orders they have given for the execution of transactions and take the necessary measures to be informed in due time of their execution or not and to make their disclosure.

According to article 14 of the Law, the information of the Company and the Hellenic Capital Market Commission includes the following information:

• the proportion of voting rights held as a result of the acquisition or disposal;
• the chain of controlled undertakings through which voting rights are effectively held, if any;
• the date on which the percentage of voting rights reached, exceeded or fell below the above thresholds, and
• the identity of the shareholder, even if he/she is not entitled to exercise voting rights in accordance with Article 10 of the Law, as well as of the person entitled to exercise voting rights on behalf of that shareholder.

The simultaneous notification of both the Company and the Hellenic Capital Market Commission is carried out by submitting to them the relevant Notification Form, a model of which has been posted on the website of the Hellenic Capital Market Commission (www.hcmc.gr) in both Greek and English. The template is accompanied by an Annex, which is completed by the obliged persons with their personal data and is submitted only to the Hellenic Capital Market Commission. When completing the Annex, it is recommended to indicate, in addition to those mentioned therein, the patronymic of the debtor. It is noted that the correct completion of the notification form is an obligation of the obliged person, who is responsible for any errors or omissions.

It is further noted that the disclosure form must be submitted to the issuer and the Hellenic Capital Market Commission duly signed. A legally signed notification is considered to be the notification signed by the obligated person himself or another person legally authorized. If the obliged person is a legal person, the declaration shall be signed by its legal representative. In any case, along with the notification, the relevant legalization documents are submitted to the Company and the Hellenic Capital Market Commission respectively, which are valid from now on until their revocation.

The legally signed notification form shall be submitted:

• regarding the Company, at its offices, 7 Alimos Alimos Avenue, Attica, 17455 (telephone + 30 210-9886187), during working days and hours, with the indication “Notification of significant changes in voting rights in accordance with Law 3556/2007”. For the convenience of shareholders, the sending can be done by email to the email address [email protected]
• as far as the Hellenic Capital Market Commission is concerned, it is submitted, legally signed to the central protocol of the Hellenic Capital Market Commission (Kolokotroni 1 and Stadiou Street, 105 62 Athens), Listed Companies Division, Permanent Information Department, with the indication “Notification of significant changes in voting rights in accordance with Law 3356/2007, as in force”. The submission of the legally signed form is also done by sending either to fax 210-33.77.243 or by email to [email protected] email address. In all cases, the form must be duly completed and accompanied by a consignment sheet containing at least the consignor’s details, signature, contact telephone number and the number of pages to be followed. The debtor must ensure that the documents are sent successfully and received by the competent protocol department.

In any case, the competent authority for the supervision of information obligations is the Hellenic Capital Market Commission.

PENALTIES

It is noted that, according to article 26 of the Law, in case of violation of the provisions of the Law and the decisions issued pursuant thereto, the Hellenic Capital Market Commission may impose, indicatively:

• a reprimand or fine of up to €1.000.000,
• administrative measures and sanctions, such as a public statement indicating the natural or legal person responsible and the nature of the infringement;
• for legal entities: a fine of up to ten million (10.000,.000) euros or up to 5% of the total annual turnover, or up to twice the amount of profits gained or losses avoided due to the infringement.
• for natural persons: a fine of up to two million (2.000.000) euros or up to twice the amount of profits gained or losses avoided due to the infringement.
• suspension of the exercise of voting rights.

For more information, shareholders of the Company may contact the Company during working days and hours (telephone +30 210-9886187) or visit the website of the Hellenic Capital Market Commission (www.hcmc.gr), on which the Law, the Decision and the Circular have been posted.