Black Sea Property AS

Related Party Transaction • Dec 27, 2018

BLACK SEA PROPERTY AS – ALLOCATIONS TO PRIMARY INSIDERS IN PRIVATE PLACEMENT

BLACK SEA PROPERTY AS – ALLOCATIONS TO PRIMARY INSIDERS IN PRIVATE PLACEMENT

Reference is made to stock exchange announcement by Black Sea Property AS (the "Company") dated 20 December 2018 regarding a private placement with gross proceeds of NOK 8,645,000 (the "Private Placement"), to be carried out through an issuance of 43,225,000 new shares in the Company (the "New Shares").

Completion of the Private Placement is subject to approval by the Company's extraordinary general meeting on 7 January 2019.

The following primary insiders was on 20 December 2018 allocated shares in the Company at a subscription price of NOK 0.20 in the Private Placement:

E.Larre Holding AS, a company owned 100% by board member and primary insider Erik Larre, has been allocated 13,000,000 New Shares in the Company. In addition, CL-Holding AS has on 20 December 2018 divested 5,234,711 shares in the Company to Gulseth Holding AS (a company wholly owned by Hans Gulseth) following a demerger. Following these transactions, Erik Larre and related parties will hold 29,451,525 shares in Black Sea Property AS, corresponding to 21.27 % of the outstanding shares and votes, based on the assumption that the Private Placement is approved by the general meeting and that the New Shares are issued.

Rødningen Invest AS, a company owned 100% by board member and primary insider Kåre Rødningen, has been allocated 1,425,000 New Shares in the Company. Following these transactions Rødningen Invest AS will hold a total of 3,252,797 shares in Black Sea Property AS, corresponding to 2.35% of the outstanding shares and votes, based on the assumption that the Private Placement is approved by the general meeting and that the New Shares are issued.

Christinedal A/S, a company owned 100% by board member and primary insider Hans Gulseth has been allocated 6,500,000 New Shares in the Company. In addition, Gulseth Holding AS (a company wholly owned by Hans Gulseth) has on 20 December 2018 taken over 5,234,711 shares in the Company from CL-Holding AS following a demerger. Following these transactions, Hans Gulseth and related parties will hold a total of 13,746,037 shares in Black Sea Property AS, corresponding to 9.93 % of the outstanding shares and votes, based on the assumption that the Private Placement is approved by the general meeting and that the New Shares are issued.

Egil Melkevik, chairman and primary insider has been allocated 500,000 New Shares personally and 500,000 New Shares through controlled company MTB Invest AS. Following these transactions, Egil Melkevik and related parties will hold a total of 1,608,194 shares in Black Sea Property AS, corresponding to 1.16% of the outstanding shares and votes, based on the assumption that the Private Placement is approved by the general meeting and that the New Shares are issued.

For further information, please contact:

Egil Melkevik, Chairman

Tel: +47 90 77 09 76

E-mail: egil.melkevik@imenco.com

About Black Sea Property AS:

Black Sea Property AS is a real estate company with holdings in a real estate project on the Black Sea coast called Aheloy Beach Resort. Aheloy Beach Resort is a partially-completed project and will upon completion comprise over 1,000 apartments as well as significant commercial space. Black Sea Property AS owns indirectly 75% of the project. Black Sea Property AS will work to finalize Aheloy Beach Resort, to realize the project's added value through the sale of residential units and hotel operations.