Notice regarding the implementation of the requirements of REGULATION (EU) 2019/2088 of 27.11.2019

and in conjunction with Art. 75a of the Markets in Financial Instruments Act and § 22 and § 23 of the Final Provisions to the Act Amending and Supplementing the Public Offering of Securities Act (State Gazette, issue 26 of 22.03.2020)

Dear clients,

Further to effective REGULATION (EU) 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 November 2019 on sustainability‐related disclosures in the financial services sector, and the provisions of DIRECTIVE (EU) 2017/828 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2017 amending Directive 2007/36/EC as regards the encouragement of long-term shareholder engagement /Directive (EU) 2017/828/, new European rules are introduced for further encouragement of the effective management and decision-making regarding long-term investments. These rules have been transposed in the Bulgarian legislation by virtue of the Act Amending and Supplementing the Public Offering of Securities Act (“AAS POSA”), published in State Gazette, issue 26 of 22.03.2020.

In accordance with § 22, para. 1 of the Final Provisions to the AAS POSA, a new Art. 75a has been added to the Markets in Financial Instruments Act (MFIA), pursuant to which an investment firm providing the service of managing a portfolio that includes shares of companies with а registered seat in a member state admitted to trading on a regulated market in a member state, shall adopt and publish an Engagement Policy as well as information about its implementation. The requirements regarding the contents of the Engagement Policy are described in Art. 75a, para. 3 of the MFIA. At the same time, a possibility is provided for deviation from this content. Art. 75a, para. 5 allows investment firms to adopt a decision not to apply an engagement policy.

UniCredit Bulbank AD has reviewed the requirements for sustainability-related disclosures in the financial services sector, the established harmonised rules for financial markets participants and financial advisors and for services related to portfolio management, as well as the transparency concerning the integration of sustainability risks and the review of unfavourable impacts on sustainability in their processes and the provision of information related to financial products.

With regard to the above, we would like to inform you that UniCredit Bulbank AD, in its capacity as an investment firm and a credit institution, is not subject to the requirements for disclosure of information related to sustainability in the financial services sector, pursuant to Regulation (EU) 2019/2088, the POSA and the MFIA, due to the fact that it does not provide the service of managing a portfolio that includes shares of companies with а registered seat in a member state admitted to trading on a regulated market in a member state.

Based on the above, UniCredit Bulbank AD does not currently apply an Engagement Policy within the meaning of Art. 75a, para. 1 of the MFIA. In case this circumstance changes, the information will be announced in due time.

Yours sincerely,

UniCredit Bulbank AD