Granolio d.d.

Governance Information • Jul 10, 2020

GRANOLIO d.d., Budmanijeva 5, Zagreb, OIB 59064993527 Security: GRNL / ISIN: HRGRNLRA0006 / LEI: 213800O3Z6ZSDBAKG321 Segment of the Regulated market: Official Market of the Zagreb Stock Exchange Home Member State: Republic of Croatia Zagreb, June 30, 2020

	CORPORATE GOVERNANCE CODE QUESTIONNAIRE FOR 2019
CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
1.	Cooperation	1.	The articles of association and other internal acts clearly determine the authorities of the supervisory and management board.	YES
1.	Cooperation	1.	The articles of association are made freely available on the company's website.	PARTIALLY	Only the articles of association is available on company's website.
1.	Cooperation	2.	The Supervisory Board has adopted the decision on which categories of decisions and legal transactions require the supervisory board's prior approval, and those on which the management board is required to consult the supervisory board before taking a decision and their summary is made freely available on the company's website.	PARTIALLY	The act was adopted but the summary is not available on company's website.
1.	Cooperation	2.	The articles of association and/or internal acts foresee that major decisions affecting the company's strategy, expenditure, risk exposure and reputation should require the supervisory board's prior approval.	PARTIALLY	The act in question covers strategy, expenditure and risk exposure.
1.	Cooperation	3.	The articles of association and/or internal acts prescribe that the supervisory board and its committees have a timely access to the company's facilities, premises, senior management and employees when necessary for the performance of their duties, and to all documents needed for these purposes.	PARTIALLY	The company's acts stipulate that the management board is obliged to make the employees of necessary specialties available to the supervisory board, and the company law stipulates the obligation to provide insight into all necessary documentation. In 2020, the Company plans to adopt amendments to the acts in such a way that the internal acts also prescribe the obligation to ensure insight into all necessary documentation.

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
1.	Cooperation	4.	The articles of association and/or internal acts prescribe that the management board should report to the supervisory board at regular intervals on the company's operational performance, financial situation, its major financial and non-financial risks and the results of its engagement with shareholders and other stakeholders.	PARTIALLY	The company's internal acts prescribe the obligation to report to the Supervisory Board on the Company's operations and condition, and legal regulations define the intervals for those reports that are required by law. The company plans to amend some of the existing acts in 2020.
1.	Cooperation	5.	The articles of association and/or internal acts prescribe that If an event occurs, or seems likely to occur, that has the potential to affect significantly the company's performance, financial position or reputation, the president of the management board must notify the supervisory board immediately.	PARTIALLY	The company's internal acts prescribe the obligation to report to the supervisory board on company's operations and condition, and management board's obligation to manage the company's affairs in accordance with regulations, which includes the obligation to report to the Supervisory Board in accordance with article 250 of the company law.
1.	Rules of Conduct	6.	The supervisory has given the approval on the rules of behaviour the members of both boards, employees and others acting on behalf of the company should follow and which also containes the rules and the sanctions in case of it's violations.	NO	The company plans to adopt the act in question in 2020
1.	Rules of Conduct	6.	The rules of behavior (or other act) is freely available on the company's website.	NO	The company will publish the act after its adoption
2.	Conflicts of interest	7.	The ban on participation in decisions is prescribed for the board members and supervisory board members where they have a conflict of interest.	YES	The ban on participation in decisions is prescribed for the board members and supervisory board members where they have a conflict of interest.

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
2.	Conflicts of interest	7.	The supervisory board has given a prior approval to a policy for managing conflicts of interest.	NO	The Company does not have a specific conflict of interest management policy. Conflict of interest in decision-making is defined by the rules of procedure of the supervisory board, the rules of procedure of the management board and the company law.
2.	Conflicts of interest	7.	The policy for managing conflicts of interest is freely available on the company's website.	NO	When the policy will be adopted as a separate act, it will be published on the company's website.
2.	Conflicts of interest	8.	Members of the supervisory board have the obbligation to inform the whole supervisory board that they are in an existing or that they have a potential conflict of interest.	PARTIALLY	The company does not have an act but the obligation arises from legal regulations. The company plans to adopt the act in question or to supplement some of the existing acts in 2020.
2.	Conflicts of interest	8.	Members of the management board have the obbligation to inform the president of the supervisory board and other members of the management board that they are in an existing or that they have a potential conflict of interest.	YES
2.	Conflicts of interest	8.	The supervisory board keeps records of all notifications related to conflicts of interest.	YES	The supervisory board keeps records of all notifications and subjects of consideration and decision-making. There are no records of conflicts of interest because there were no cases of conflicts of interest.
2.	Conflicts of interest	9.	Where a management or a supervisory board member has reason to believe that another member of a management or supervisory board is in an an existing or potential conflict of interest, they have the obligation to inform the president of the supervisory board and/or the deputy of the president of that board about that.	NO	The company plans to prescribe the obligation in question when amending the existing acts in 2020

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
2.	Competition ban	10.	Members of the supervisory and management board are not engaged in activities that compete with the company's business, they are not members of management or supervisory board of companies that are engaged in such activities niether they own more than 5% of shares in such company's.	YES
2.	Competition ban	10.	Members of the supervisory and management board who have shares in companies that compete with company's business have informed the company secretary about all their holdings in such companies, and details of these holdings should are freely available on the company's website.	YES
2.	Related Party Transactions	11.	No transactions involving members of the management or supervisory boards and the company (or persons related to either party) can be made without prior approval of the supervisory board.	YES
2.	Related Party Transactions	11.	The fair value of each material transaction should be confirmed by an independent expert prior to the transaction, and whose report must be made freely available on the company's website.	NO	The company did not prescribe this obligation by an act.
2.	Related Party Transactions	12.	The company has adopted the procedures for approving and publication of transactions between the members of the management board or supervisory board and the company (or persons associated with either party).	NO	The company does not have an act but the obligation arises from legal regulations.
2.	Related Party Transactions	12.	The audit committee reviews the effectiveness of these procedures once a year.	NO	Procedures have not been adopted
3.	Role of the supervisory board	13.	The supervisory board is responsible for appointing and dismissing members of the management board, and for recommending candidates for the supervisory board to the general meeting.	YES
3.	Role of the supervisory board	13.	The supervisory board has ensured that formal and transparent procedures are in place for appointments to both management and supervisory boards.	NO	The company plans to adopt the procedure in 2020
3.	Role of the supervisory board	14.	The supervisory board has set a target for the percentage of female members in the supervisory and management boards to be achieved within the next five years and has adopted a plan for the implementation of this goal. The target and the plan have been published in the annual report.	NO	The company plans to adopt the subject goal and plan in 2020

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
3.	Role of the supervisory board	14.	The report of plan progress has been publicized in the annual report.	NO	The company plans to adopt the subject goal and plan in 2020
3.	Role of the nomination committee	15.	The nomination comitee has all the tasks listed in the article 15 of the code.	NO	The nomination committee has not been established
3.	Election of supervisory board members by the general meeting	16.	When proposing candidates for the supervisory board to the general meeting for election, the company shall make freely availabe among the materilas of the general meeting all the information listed in the article 16 of the code.	YES
3.	Election of supervisory board members by the general meeting	16.	The information defined in the article 16 of the code are freely available on the company's website.	NO
3.	Election of supervisory board members by the general meeting	17.	The materials for the general meeting contain all the information which are listed i the article 17 of the code.	NO	At subsequent appointments, the information in question will be included in the materials for the general meeting
3.	Election of supervisory board members by the general meeting	18.	The data listed in article 17 of the code are freely available on the company's website even when workforce representatives or other supervisory board members are appointed who are not elected by shareholders at the general meeting	NO	Upon subsequent appointments, the information in question will be freely available on the company's website

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
4.	Responsibilities of the supervisory board	19.	The supervisory board has all the tasks listed in the article 19 od the code.	PARTIALLY	Succession planning and the manner in which the management board cooperates with shareholders and other stakeholders are not explicitly stated in the company's acts.
4.	Composition	20.	The supervisory board has developed a supervisory board profile which specifies the minimum number of members and the combination of skills, knowledge and education, as well as professional and practical experience that is required in the supervisory board.	NO
4.	Composition	21.	The supervisory board includes members with different genders, ages, backgrounds and experience in order to ensure different perspectives in decision-making.	PARTIALLY	The Supervisory Board does not include members of different genders
4.	Composition	22.	The most part of the supervisory board members is independent according to the definition from the annex A of the code.	NO	The supervisory board is currently composed of four members, two of whom are independent
4.	Composition	22.	The president or the deputy of the president of the supervisory board are independent.	YES
4.	The president	23.	The president of the supervisory board has the tasks defined in the article 23 of the code.	PARTIALLY	The acts of the Association do not state taxatively all the responsibilities of the president of the supervisory board from article 23rd
4.	Board committees	24.	The supervisory board has established the appointment committee.	NO
4.	Board committees	24.	The supervisory board has established the remuneration committee.	NO
4.	Board committees	24.	The supervisory board has established the audit committee.	YES
4.	Board committees	24.	The supervisory board has stipulated the mandate and activities of each it's committee.	PARTIALLY	Determined only for the audit committee which is established

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
4.	Board committees	26.	Each comittee of the supervisory board is composed by members who have necessary skills, knowledge and education as well as professional and practical experience for effective performance of that board functions.	PARTIALLY	Only for the audit committee which is established
4.	Board committees	27.	Each board of the supervisory board has at least three members	PARTIALLY	Only audit committee which is established
4.	Board committees	27.	The most part of members of each board of the supervisory board is independent (according to the definition in the annex A of the code).	NO	2 of 3 members of the audit committee are not independent
4.	Board committees	27.	Members of the management board are prohibited from being members of the supervisory board.	YES
4.	Board committees	28.	The job description of each board of the supervisory board is freely available on company's website.	NO	The company plans to publish the list of audit committee tasks on its website in 2020
4.	Board committees	28.	The company includes the yearly work report of each board of the supervisory board into the annual report and information on number of held meetings and board members.	PARTIALLY	Only for the audit committee which is established
4.	Time commitment	29.	The minimum expected time commitment of each supervisory board member is specified in the moment of their appointment.	NO
4.	Time commitment	29.	In the annual report, the company has published a record of each member's attendance at board and board committees meetings.	NO
4.	Time commitment	30.	The articles of association and/or other internal acts of the company foresee the obligation of the management board members to inform the company secretary on their membership in the supervisory board or in the management board of other companies.	NO	The procedure in case of conflict of interest is defined in the rules of procedure of the supervisory board, the expansion of which with the obbligation in question is planned in 2020.
4.	Frequency and format of meetings	31.	Supervisory board meetings are held at least once every three months.	YES

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
4.	Frequency and format of meetings	31.	The supervisory board has adopted a working plan which includes the timing and agenda of future meetings.	YES
4.	Frequency and format of meetings	31.	The supervisory board committees meetings are held as ofthen as necessary for effective performance of their duties and they report regulary to the supervisory board about their activities.	PARTIALLY	Only audit committee which is established.
4.	Frequency and format of meetings	32.	The supervisory board meetings can be held without the presence of the management board members when the supervisory board considers it appropriate.	YES
4.	Frequency and format of meetings	32.	The persons which are not members of the committees of the supervisory board may attend the board sessions only when invited by the board.	YES
4.	Support	33.	The company has appointed a person who will perform the duties of the company's secretary.	YES
4.	Support	33.	In accordance with the articles of association and other internal acts the company's secretary is responsible to act in accordance with supervisory board procedures, to advise the supervisory board on governance matters, to give support to the president of the supervisory board and give help to supervisory board and to supervisory board committees to function efficiently.	PARTIALLY	The company has appointed a person who will perform the duties of the secretary of the company from article 33 of the code, however, the company has not adopted an act on this, nor is there a position of secretary of the company in the systematization of working places.
4.	Quality and timeliness of information	34.	The job desctription of the members of the supervisory board and/or internal acts of the company foresee the obligation to provide to supervisory board members all the materials necessary for the supervisory board meeting at least one week before the meeting.	NO	The company's acts set a deadline of 5 days.

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
4.	Quality and timeliness of information	34.	The job desctription of the supervisory board committees and/or internal acts of the company foresee the obligation to provide to members of the supervisory board committees all the materials necessary for the supervisory board committee meeting at least one week before the meeting.	NO	The job description of the audit committee foresees the delivery of materials within a deadline that will provide them with sufficient time to study the materials before the meeting.
4.	Quality and timeliness of information	35.	The articles of association and/or other internal acts foresee that minutes of the supervisory board meeting must be freely available to all members of the supervisory board.	YES
4.	Quality and timeliness of information	35.	The supervisory board meeting minutes contain the information on results of the voting, including details on individual members voting.	YES
4.	Quality and timeliness of information	36.	The supervisory board is entitled to receive information or advice from parties outside of the company at the company's expense if the supervisory board considers it necessary to carry out its duties effectively. The procedure for doing so are specified in internal acts adopted by the management board with prior approval by the supervisory board.	NO
4.	Training and development	37.	All supervisory board members have received the introduction training for their role on appointment.	PARTIALLY	The members of the supervisory board were acquainted with the rules of procedure of the supervisory board and their legal obligations, especially with regard to the management of inside information.
4.	Training and development	37.	All supervisory board members are continuously beeing trained and educated in order to improve their skills and knowledge.	PARTIALLY	The company's acts do not prescribe such practice.
4.	Training and development	38.	The supervisory board members regulary receive the updates and briefings from the management board and experts on matters relevant to the company and to their duties as supervisory board members.	PARTIALLY	The supervisory board receives such notifications from the management board and from experts as needed.
4.	Supervisory board evaluation	39.	The supervisory board has evaluated it's effectiveness in last 12 months.	NO
4.	Supervisory board evaluation	39.	The supervisory board has evaluated the individual results of it's members in last 12 months.	NO

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
4.	Supervisory board evaluation	39.	The evaluation of the supervisory board effectivnes was led by the president,or by the deputy president of the supervisory board.	NO
4.	Supervisory board evaluation	40.	The evaluation of the supervisory board included the evaluation of all circumstances listed in article 40 of the code.	NO
4.	Supervisory board evaluation	41.	The annual report includes the report on evaluation of the supervisory board and it's commettees in which all the circumstances listed in the article 41 of the code have been evaluated	NO
5.	Responsibilities of the management board	42.	The duties of the management board include all activities listed in article 42 of the code.	YES
5.	Responsibilities of the management board	43.	The management board has adopted and the supervisory board has approved the rules of procedures of the management board which defines all listed in the article 43 of the code.	YES
5.	Responsibilities of the management board	44.	In case of group, the management board of the parent company is responsible to ensure the effective oversight of the activities of the other companies in the group.	YES
5.	Responsibilities of the management board	44.	The articles of association and/or internal acts of the company contain the rules which define the reporting responsabilities and reporting arrangements at the parent company and subsidiary level.	PARTIALLY	There are no formally adopted rules. The finance managers of the daughter companies are responsible for reporting.
5.	Composition	45.	The supervisory board ensures that the management board maintains a management board profile which specifies the minimum number of members and the combination of skills, knowledge and education, as well as professional and practical experience that it requires.	PARTIALLY	The supervisory board ensures that the management board has a sufficient number of members for the effective execution of it's responsibilities but estimates that currently the adoption of the formal act on profile of the management board is not necessary for effective performance of the management board responsabilities.

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
5.	The president	46.	The responsibility of the president of the management board for all activities listed in the article 46 of the code.	YES
5.	Limits on other appointments	47.	Internal acts of the company foresee that the members of the board must obtain the prior consent from the supervisory board before accepting the nomination to the management board or to the supervisory board of the company that is not the part of the same group.	NO
5.	Limits on other appointments	47.	By internal acts of the company it is foreseen the prohibition to members of the board to hold more than two positions in the management board or supervisory board of such companies.	NO
5.	Board evaluation	48.	The supervisory board has evaluated the effectiveness of the arrangements for cooperation between the supervisory and management boards, and the adequacy of the support and information it receives from the management board in last 12 months.	YES
5.	Board evaluation	48.	The results of the evaluation of the arrangements for coopeeration between the supervisory and management board are included in the annual report.	NO
5.	Board evaluation	49.	The management board has evaluated its own effectiveness and that of its individual members in last 12 months.	NO
5.	Board evaluation	49.	The management board has sent the report on conclusions of the evaluations of its own effectiveness and that of its individual members to the supervisory board.	NO
6.	Role of remuneration committee	50.	The responsibilities of the remuneration committee include all the activities listed in the article 50 of the code.	NO	The remuneration committee has not been established
6.	Remuneration of management board members	51.	The supervisory board determines the annual remuneration of each management board member, based on the recommendations of the remuneration committee and in accordance with the approved remuneration policy.	NO	The remuneration committee has not been established, the remuneration policy has not been approved.
6.	Remuneration of management board members	52.	The level of remuneration for management board members is appropriate in relation to the agreed strategy and risk appetite, the economic environment within which the company operates, and the pay and conditions of employees within the company.	NO

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
6.	Remuneration of management board members	53.	The remuneration policy prescribes that the management board member may not dispose of shares which were awarded to him as a part of remuneration for at least two years from the day on which the shares were awarded to him.	NO	The remuneration policy has not been adopted, the shares have not been awarded as part of the remuneration.
6.	Remuneration of management board members	53.	The remuneration policy prescribes that the management board member may not exercise options to buy shares which were awarded to him as a part of the remuneration at least two years from the day on which the options were awarded to him.	NO	The remuneration policy has not been adopted, the shares have not been awarded as part of the remuneration.
6.	Remuneration of management board members	53.	The remuneration policy includes provisions which specifying the circumstances in which a part of the management board member's remuneration would be withheld or recovered.	NO	The remuneration policy has not been adopted.
6.	Remuneration of supervisory board members	54.	The level of remuneration for the president of the supervisory board and other supervisory board members reflects their time commitment and responsibilities involved, including time commitment and resposibilities in board committees.	NO	The remuneration is determined by the decision of the general meeting and reflect their time commitment, but do not provide a special remuneration for membership in the committees of the supervisory board.
6.	Remuneration of supervisory board members	55.	The remuneration policy and/or internal acts of the company ban the inclusion of the of variable or other performance-related elements into the remuneration of the supervisory board.	NO	The remuneration is determined by the decision of the general meeting which does not include the payment of the variable part. To the general meeting it will be proposed in 2020 to make a decision by which it will be expressly prohibited.
6.	Reporting on remuneration	56.	The remuneration policy was approved by the shareholders at the general meeting.	NO	The remuneraton policy has not been adopted. The general meeting has adopted a decision in 2011 on the remuneration for the president and members of the supervisory board, and to the general meeting will be proposed to adopt a new decision in 2020.

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
6.	Reporting on remuneration	56.	The approved remuneration policy is freely available on the company's website.	NO	The remuneraton policy has not been adopted.
6.	Reporting on remuneration	57.	The annual remuneration report includes the information on the remuneration of all individual board members and other information listed in the article 57 od the code.	NO	The data on remuneration of each member of the supervisory board have been published in the financial reports of the company in total amount.
7.	Roles of the supervisory and management boards	58.	The management board has adopted, with the prior consent pof the supervisory board, a policy specifying the nature and extent of the risks the company needs and is willing to take in order to achieve its long-term strategic objectives (the "risk appetite").	NO	The management board has adopted, with the consent of the supervisory board, the business plan which partly, through the investement plan and similar, determines the nature and extent of risks whch the company must
7.	Roles of the supervisory and management boards	59.	The responsibility of the management for all activities listed in Article 59 of the code is prescribed.	YES
7.	Role of the audit committee	60.	The job description of the audit committee includes all activities listed in Article 60 of the code.	YES
7.	Role of the audit committee	61.	Audit committee, supervisory board or some of it's committees has undertaken all the activities listed in the article 61 od the code.	PARTIALLY	By the rules of procedure of the audit committee the activities of supervising the application of procedures for reporting violations of the law or internal rules of conduct were not covered. The new rules of procedure will cover this activity also.
7.	Relations with the external auditor	62.	The audit committee oversees the process of selecting and appointing the external auditor in accordance with the requirements of the law, and makes recommendations to the supervisory board on the choice of external auditor and the terms of his appointment.	YES
7.	Relations with the external auditor	63.	The audit committee has approved the external auditor's annual work plan in last 12 months which covers the scope and content of the activities to be audited.	NO	The audit committee plans to adopt that plan in 2020.

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
7.	Relations with the external auditor	63.	The audit committee meetsthe external auditor as needed to discuss issues identified in the course of the audit, and to monitor the quality of the services provided.	YES
7.	Relations with the external auditor	64.	The responsibility of the audit committee for the supervision, independence and objectivity of the external auditor is prescribed.	YES
7.	Relations with the external auditor	64.	The audit committee has approved the policy on the provision of permitted non-audit services by the external auditor.	NO	The audit committee approves the services of the external auditor which are not the audit services, however, the policy as an act has not been adopted.
7.	Risk management and internal control	65.	The audit committee has reviewed the effectiveness of the risk management and internal control systems as a whole at least once a year.	YES
7.	Risk management and internal control	65.	The audit committee makes recommendations to the supervisory and management boards as necessary, regarding the effectiveness of the risk management and internal control systems.	YES
7.	Risk management and internal control	66.	The company maintains an effective risk management system that is adequate to ensure a reliable risk identification, measurement, response, reporting and their monitoring.	PARTIALLY	There are no formally adopted procedures. The internal control of operations and the management of risks partly is beeing done through the activities of the business function controlling, and partly through the activities of the management bodies of the company and external auditors and certification companies
7.	Risk management and internal control	66.	The company has designated the clear internal responsibilities for maintaining the risk management system and a clear procedure of contacts maintanance by the responsable persons with the audit committee.	PARTIALLY	There are no formally adopted procedures.

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
7.	Risk management and internal control	67.	The company has established the internal audit function responsible for internal control system monitoring, including the risk management.	NO	The internal control of operations and the management of risks partly is beeing done through the activities of the business function controlling, and partly through the activities of the management bodies of the company and external auditors and certification companies
7.	Risk management and internal control	67.	The audit committee has approved the internal audit work plan in last 12 months.	NO	The internal audit function has not been established.
7.	Risk management and internal control	67.	The audit committee recives the internal auditor's reports and monitors the implementation of his recommendations.	NO	The internal audit function has not been established.
7.	Risk management and internal control	68.	The audit committee is obliged to recommend the appointment or dismissal of the head of the internal audit function to the supervisory board.	NO	The internal audit function has not been established.
7.	Risk management and internal control	68.	If there is no internal audit function in the company, the audit committee has reviewed the need for it once a year, as part of its review of the internal control system.	YES
7.	Whistle-blowing	69.	The management board has adopted, with the prior approval of the supervisory board, a procedure for reporting actual or suspected breaches of the law or of the company's code of conduct.	PARTIALLY	The rules on protection of the whistleblowers has been adopted without the prior consent of the supervisory board.
7.	Whistle-blowing	69.	The procedure ensures that employees or external stakeholders do not suffer negative consequences if they report suspected misconduct.	YES

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
7.	Whistle-blowing	69.	The details about the procedure for reporting are freely available on company's website.	NO	The rules on protection of the whistleblowers has been published on the company's bulletin boards and the company plans to publish it on the company's website in 2020.
7.	Whistle-blowing	70.	The articles of association and/or other internal acts foresee the obligation of the management board to inform the supervisory board about all identifyed irregularities and to agree the measures which have to be implemented.	PARTIALLY	The company's acts prescribe the management board obligation to report to supervisory board on operations and condition of the company.
7.	Whistle-blowing	70.	The audit committee has reviewed the effectiveness of the procedure and how it has been applied in last 12 months.	NO	There were no reports of irregulaties
8.	Use of the company website	71.	The company should use its website as the main medium for disclosure of All inforamtion that the company is required to disclose in accordance with the law, listing rules, this code and its own articles of association are freely available on company's website.	YES
8.	Use of the company website	72.	All information defined by the article 72 of the code are freely available on company's website and can be easily accessed.	PARTIALLY	The company's website contains the company's annual report, half year and quarterly reports and other financial information required to be published, information on the composition and members of the supervisory board and of the management board, the company's articles of association, internal rules and how to report irregularities, all materials connected to general meeting sessions, including decisions from these sessions.
8.	Use of the company website	73.	The company has ensured that the information on company's website are kept up-to-date and published within the deadlines prescribed by law and regulations.	YES

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
8.	Use of the company website	73.	All data on the website are freely available in both Croatian and English language.	YES
8.	Annual report	74.	The annual report includes all the information listed in the article 74 of the code.	NO
9.	Relations with shareholders	75.	The company has ensured that all shareholders, irrespective of the number or class of shares they hold, have equal access to information about the company and how they can exercise and protect their rights.	YES
9.	Relations with shareholders	76.	The company has established effective formal mechanisms to enable minority shareholders to submitt questions directly to the presidents of the supervisory and management board and the details of how these mechanisms operate should be freely available on the company's website.	PARTIALLY	On the company's website, it is possible to fill in the form for comments and inquiries, which are then distributed internally according to the type of inquiries and comments directly to the responsible persons or to those to whom the comment or question was addressed.
9.	Relations with shareholders	77.	The company has designated an individual as the investor relations contact for all shareholders and contact details of that individua are freely available on the company's website.	PARTIALLY	The company plans to implement the provision in question in 2020.
9.	General meeting	78.	The articles of association and/or internal acts of the company do not place any restrictions on the ability of shareholders to convene or participate in a general meeting, or to place items on the agenda.	YES
9.	General meeting	79.	The articles of association and/or internal acts of the company provide to all shareholders the opportunity to exercise their votes by proxy without limitations.	YES
9.	General meeting	79.	The articles of association and/or internal acts of the company provide to all shareholders the opportunity to exercise their votes electronically without limitations.	NO	By the articles of association is foreseen the voting only by lifting the voting cartoon or by handling over the voting paper.
9.	General meeting	79.	The explanation of other different means by which shareholders can exercise their votes are included in the documents for the general meeting.	NO	By the articles of association is foreseen the voting only by lifting the voting cartoon or by handling over the voting paper.

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
9.	General meeting	80.	The notice of the general meeting was published no later than 30 days before the day of its holding.	YES
9.	General meeting	80.	The agenda, resolutions and all other documents required for the general meeting are freely available on the company's website.	YES
9.	General meeting	80.	All documents are available on Croatian and English language.	YES
9.	General meeting	81.	All the persons listed in the article 81 of the code have been present at the general meeting in last 12 months.	YES
9.	General meeting	81.	The external auditor has been present at the general meeting on which the annual financial reports were presented.	YES
9.	General meeting	82.	The company has made the decisions of the general meeting freely available on it's website.	YES
9.	General meeting	82.	The company has made the answers to questions asked at a general meeting freely available on its website within 30 days of the meeting.	NO	There were no questions
10.	Corporate Social Responsibility	83.	The supervisory and the management board have agreed and have adopted the policies prescribed in the article 83 of the code.	NO	The policies in question are planned to be adopted in year 2020.
10.	Corporate Social Responsibility	83.	The policies are freely available on company's website.	NO	The policies in question are planned to be adopted in year 2020.
10.	Corporate Social Responsibility	84.	When the management board seeks the supervisory board's prior approval on decisions, the supporting documents explain how the recommended action is consistent with the policies related to impact assesment of the company's activities to environment and social community, with the policies related to human rights and the rights of employees safeguarding and with the measures related prevention and sanction of corruption and bribery.	NO	The policies in question have not been adopted.
10.	Stakeholder engagement	85.	The supervisory board and the management board have jointly identifyed who they consider to be the company's key stakeholders.	PARTIALLY	There are no formally adopted acts.

CHAPTER	PROVISION	ARTICLE	QUESTION	ANSWER	EXPLANATION
10.	Stakeholder engagement	85.	The management board has ensured that there are effective mechanisms in place for regular interaction with key stakeholders, as well as for informing the supervisory board about the results of these communications.	YES
10.	Stakeholder engagement	86.	The supervisory board is entitled, with prior notice to the president of the management board, to organize the meetings with external stakeholders when it considers it necessary.	NO
10.	Stakeholder engagement	87.	In the mandates of each committee of the supervisory board it is foreseen in which purposes the president of the committee can communicate directly with the company's stakeholders and which procedure has to be followed.	NO