Altrecom PLC

Governance Information • Jan 20, 2025

APPENDIX 13

CONCENTRATED STATEMENT FOR THE FREE FLOAT OF THE SHARE CAPITAL OF COMPANY: ALTRECOM PLC

A.	Bodies of Administration - Management and Surveillance [(Article 137(3)]	Total number of shares	Percentage of the total number of shares
1.	Chairman of the Board
	Natalia Kyriacou (Executive Director)	0	0.00%
2.	Members of the Board (Names)
2.1	Cleo Koushos Cros (Non-Executive Director)	1	<0.01%
2.2	Martha Lambrianou (Non-Executive Director)	1	<0.01%
3	General Manager	0	0.00%
4	Financial Manager	0	0.00%
5	Head of Accounting Department	0	0.00%
6	Secretary	0	0.00%
7	Auditors (names of partners/employees)	0	0.00%
8	Buy Back	0	0.00%
9.	Employees Provident Funds	0	0.00%
	(Names of funds)
в.	Major Shareholders (over 5%)
B.1	Esmena Investments Limited	108,371,907	99,999992%
	TOTAL	108,371,909	93,999994%
C.	Company Employees	0	0.000000%
	FREE FLOAT TO THE PUBLIC	7	<0.01%
	TOTAL NUMBER OF LISTED SHARES	103,371,916	100%

AS AT 31/12/2024

Personal data collected by the CSE upon submission of this application are processed for carrying out the transaction / operation / action / service requested, fulfilling the duties of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding authorly and for the public increat and to volume in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position
Chairman

Secretary

SOPHIA DEMETRIADOU

NAME - SURNAME

NATALIA KYRIACOU

For and on behalf of SPEEDY SECRETARIAL

SIGNATURE DATE 14/01/2025 14/01/2025

033

A.	Market in which the securities of the company are listed
B.	Information:	Number of Persons	Number of Persons
B.1	Natural Persons	9
B.2	Legal Persons	1	10
B.3	Total (B1 + B2)
B.4	Members of the Board of Directors
	i. Directly	2
	Through persons who hold shares in ii. their name, but for the account of every Member of the Board	0
	iii. Through undertakings controlled by every Member of the Board	0
	iv . Through persons acting in concert with every Member of the Board	0
B.5	Major shareholders over 5%	1
B.6	Total (B4 + B5)		(3)
C.	TOTAL (B3 - B6)		7

concentrated elements of the FREE FLOAT of the Share capital of the company

Personal data collected by the CSE upon submission of this application are processed for carrying out the transaction / operation / action / service requested, fulfilling the duties of the CSE in the exercise of public transaction 7 operation Paction Foor roompliance with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position	NAME - SURNAME	SIGNATURE ,	DATE
CHAIRMAN			NATALIA KYRIACOU : Meero K. - 14/01/2025

A.	Bodies of Administration -	Total number of	Percentage to the	Trading Code /
	Management and Supervision	shares	total number of shares	Trading Account
1.	[(Article 137(3)] Chairman of the Board
	Name : NATALIA KYRIACOU
1.	Directly	0	0%
II.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	0	0%

FREE - FLOAT OF THE SHARE CAPITAL OF THE COMPANY: ALTRECOM PLC AS AT 31/12/2024

Personal data collected by the CSE upon submission of this application are processed for carrying out the transaction / operation / service requested, fulfilling the duties of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position	NAME - SURNAME	SIGNATURE	DATE
CHAIRMAN		NATALIA KYRIACOU J Heerop - 14 101 12025

		Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
2.	Member of the Board Name : CLEO KOUSHOS CROS	1	<0.01%	AATP/ 2004542077
1.	Directly
11.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	0	0%

Note: Complete the number of forms as are required for every member of the appropriate numbering 2.1, 2.2, 2.3 etc (place the second numeral after the number 2 in the above form).

Personal data collected by the CSE upon submission of this application are processed for carrying out the transaction / operation / service requested, fulfilling the dutles of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position

NAME - SURNAME non-executive director Cleo Koushos cros

4

		Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
2.	Member of the Board Name : MARTHA LAMBRIANOU	1	<0.01%	AATPI 2004914053
1.	Directly
11.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	0	0%

Note: Complete the number of forms as are required for every member of the appropriate numbering 2.1, 2.2, 2.3 etc (place the second numeral after the number 2 in the above form).

Personal data collected by the CSE upon submission of this application are processed for carrying out the transaction / operation / service requested, fulfilling the duties of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position

DATE 14/01/2025

		Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
3.	General Manager Name :	0	0%
1.	Directly
II.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	0	0%

Personal data collected by the CSE upon submission are processed for carying out the Fersonal uate onlood by the Service requested, fulfilling the duties of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position	NAME - SURNAME	SIGNATURE/	DATE
		CHAIRMAN NATALIA KYRIACOU THEER R-1410112025

		Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
4.	Financial Manager Name :	0%	0%
1.	Directly
II.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	0	0%

Personal data collected by the CSE upon submission are processed for carrying out the roloonal adde of the I service requested, fulfilling the duties of the CSE in the exercise of public transaction 7 operation 7 dolf not 100 100 100 account in the dated on the virther information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position	NAME - SURNAME	SIGNATURE	DATE
		CHAIRMAN NATALIA KYRIACOU SHEER R- (410112025

		Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
5.	Head of Accounting Department Name :	0	0%
1.	Directly
II.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	0	0%

Personal data collected by the CSE upon submission are processed for carrying out the reloonar add obliotton / service requested, fulfilling the duties of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position	NAME - SURNAME	SIGNATURE)	DATE
			CHAIRMAN NATALIA KYRIACOU Theer Meerop - 14/01/2025

		Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
6.	Secretary Name : SPEEDY SECRETARIAL SOLUTIONS LIMITED	0	0%
1.	Directly
11.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	0	0%

Personal data collected by the CSE upon submission are processed for arrying out the Personal data Collected by the Society Fulfiling the Mothe of the CSE in threexercise of public
transaction / operation / service requested, fulfiling the lobigations. Firth authorly and of in the public meess and of complaned in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position	NAME - SURNAME	SIGNATURE	DATE
SECRETARY	SOPHIA DEMETRIADOU		1410112025
	For and on behalf of SPEEDY SECRETARIAL SOLUMONS LIMITED

		Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
7.	Auditors Name : FINCAP ADVISERS LIMITED	0	0%
1.	Directly
11.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	0	0%

Note: Forms should be completed for any partners and employees which are involved in the auditing of the accounts which hold shares of the company either directly, giving the appropriate numbering 7.1, 7.2, 7.3 etc (the second numeral should be placed next to the number 7 above). SEE EXPLANATIONS, NUMBER 4

Personal data collected by the CSE upon submission are processed for carying out the transaction / operation / action / service requested, fulfilling the duties of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home/l 2 22

Position NAME - SURNAME

AUDITORS ANGELOS THEODOROU

For and on behalf of FINCAP ADVISERS LTD

1 SIGNATURE DATE ប្រ 10112025

		Total number of shares	Percentage to the total number of shares	. Trading Code / Trading Account
8.	Buy Back	0	0%
	TOTAL	0	0%

Personal data collected by the CSE upon submission are processed for carrying out the transaction / operation / action / service requested, fulfilling the duties of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position
CHAIRMAN	NATALIA KYRIACOU : MERRER - 1410112025

		Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
9.	Employees Provident Funds Names of funds:	0	0%
1.	Directly
II.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	0	0%

Note: Complete the number of forms according to the Employees Provident Funds giving the numbering 9.1, 9.2, 9.3 etc (the second numeral should be placed after the number 9 above).

Personal data collected by the CSE upon submission of this application are processed for carrying out the transaction / operation / service requested, fulfilling the duties of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position NAME - SURNAME

CHAIRMAN

NATALIA KYRIACOU

DATE 14/01/2

B.	Major Shareholders (over 5%)	Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
B.	Name: ESMENA INVESTMENTS LTD			AATPI 2004915529
1.	Directly	108,371,907	99.999992%
II.	Through persons holding shares in their name but for the account of the above mentioned person (names)
III.	Through undertakings controlled by the abovementioned person (names)
IV.	Through persons acting in concert with the abovementioned person (names)
	TOTAL	108,371,907	99.999992%

Note: Complete the number of forms according to the najor shareholders giving the appropriate numbering B.1, B.2, B.3. etc (the number should be placed after the letter B in the form above).

Personal data collected by the CSE upon submission of this application are processed for carrying out the transaction / operation / action / service requested, fulfilling the duties of the CSE in the exercise of public transaction / operation / addon't our not 'requocol)'nnew with legal obligations. Further information regarding
and / or in the public interest and for compliance with legal the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position

NAME – SURNAME

SIGNATURE/

DATE

MAJOR SHAREHOLDER

MARIIA NIKOLENKO For and on behalf of ESMENA INVESTMENTS LTD

C.	Company Employees	ID Number	Total number of shares	Percentage to the total number of shares	Trading Code / Trading Account
			0	0%
	TOTAL
	Number of Employees who hold shares			0
	Number of Employees who do not hold shares			0

Personal data collected by the CSE upon submission of this application are processed for carrying out the r ersonal data Gollotted by the Soc apon Gabinet and processor and procosoft of the CSE in the exercise of public authority and / or in the public interest and for compliance with legal obligations. Further information regarding addition and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position CHAIRMAN NAME - SURNAME

NATALIA KYRIACOU

DATE 025

APPENDIX A

TOTAL NUMBER OF ISSUED BUT NOT LISTED SHARE CAPITAL	Total number of shares	Total
(a) same category	0	0
(b) other category	0	0

Personal data collected by the CSE upon submission of this application are processed for carrying out the relisonal until conceded by the Use requested, fulfilling the duties of the CSE in the exercise of public transacton 7 operation 7 added 7 60 rios 15quondly acce with legal obligations. Further information regarding the collection and processing of personal data is included in the CSE privacy policy, which is posted on the following website: http://www.cse.com.cy/en-GB/home//

Position	NAME - SURNAME	SIGNATURE	DATE
CHAIRMAN	NATALIA KYRIACOU		1410112025
Secretary	SOPHIA DEMETRIADOU For and on behalf of SPEEDY SECRETARIAL SOLUTI	CELL	14/01/2025

EXPLANATIONS:

• 1. Controlled undertaking means every undertaking in which a person or a number of persons acting in concert, has:
  2. i. the majority of voting rights of the shareholders or partners or,
  3. ii. the right to appoint or remove the majority of the members of the body of administration, management or surveillance and is at the same time a shareholder or partner of the company or,
  4. iii. is a shareholder or partner and by himself controls the majority of the shareholders or partners, pursuant to an agreement entered into with other shareholders or partners of the company.

The rights of every other controlled undertaking as above, as well as the rights of every person who acts in its own name but on behalf of the parent undertaking or any other controlled undertaking, are added to the voting rights and the right of appointment or removal of the parent company.

• 1. Persons acting in concert, means persons which with coordinated actions or pursuant to agreement, collaborate with each other and includes the following categories of persons by rebuttable presumption:
  2. i. the spouse and blood relatives up to first degree of kindred of the persons which are referred to in section (3) of Article 137 (3).
  3. ii. companies in which any of the persons referred to in section (3) possess either on its own, or jointly with the other persons that are referred to in section (3), at least twenty percent (20%) of the voting rights,
  4. iii. provident funds of an undertaking controlled by any of the persons that are referred to in section (3),
  5. iv. partners of any of the persons that are referred to in section (3).
• 1. Blood relatives up to first degree of kindred include the following persons: Parents, spouse, children.

The relationship of the persons acting in concert with each member of the Board of Directors shall be written in parenthesis eg spouse, children, parents.

1. The term "Auditors" referred to in paragraph «a» of Article 137(3) of the Law of the Stock Exchange includes all of the partners of the audit firm and all its employees which are involved in the company's accounts. As is stated on the forms should be completed for every partner and every employee who is involved in the auditing of the company's accounts who directly holds shares of the company. The term «indirectly» includes capital held by persons holding shares in their name but on behalf of a partner or an employee involved in the accounts of the company, capital held by undertakings controlled by a partner or an employee in the auditing of the accounts of the company and capital held by persons acting in concert with a partner or an employee involved in the auditing of the accounts of the company (based on the definitions of paragraphs 1 and 2 above). For partners or employees who are involved in the audit of the company's accounts who do not hold shares of the company, a written statement regarding this should be made as follows:

«The (other) partners and (other) employees involved in the accounts of ...................................................................................................... (company name) do not hold shares of the company :

• (a) Directly or,
• (b) through persons who hold shares in their name but on behalf of any partner or any employee in the audit of the company's accounts or,
• (c) through undertakings controlled by a partner or an employee in the audit of the company's accounts or,
• (d) through persons acting in concert with a partner or an employee in the audit of the company's accounts, according to the interpretation which is given in Article 137 (4) of the Cyprus Stock Exchange Law»

Note: The words "other" are not included in the event that all the employees involved in the audit of the company's accounts do not possess shares of the company directly (as is explained above).

• 1. The phrase "companies in which any of the persons referred to in section (3) of Article 137 (3) of the Cyprus Stock Exchange Law" which is included in subparagraph (ii) of the interpretation of persons acting in concert (paragraph 2 above), means a company in which any of the persons which are referred to in section (a) the Article 137 (3) of the Cyprus Stock Exchange Law, holds directly over 20% of the shares with voting rights.
• 1. The participation of a trust in a company is attributable to the final beneficial owners) by rebuttable presumption.
• 1. Where a participation in the listed company under consideration should be stated more than once, this should be stated only once and a relevant reference for the matter should be given in a separate page of clarifications.

For example if the Chairman of the Secretary of the listed company under consideration hold 25% and 27% of the voting rights of company A respectively, the participation of company A in the listed company should be charged to either only the President or only the Secretary, making a relevant reference to this fact.

• 1. Where a member of the administrative, managerial or supervisory bodies of the listed company is simultaneously a major shareholder (over 5%), the inclusion of his participation in category B "Major Shareholders" is not required.
• 1. Regarding subparagraph (ii) of the interpretation of persons acting in concert (see paragraph 2 above), it is clarified that for the expression "jointly", the participation of the declaration in a company is not required for that person to be considered to fall within the provisions of this subparagraph.

For example if the person making the declaration does not hold shares directly in a company A, but his spouse holds over 20% of the voting rights, this company is considered to fall within the provisions of the above subparagraph, that is, it is considered to be a person acting in concert with the person making the declaration.

• 1. Where the space given in the forms is not sufficient the remaining items should appear on the back of each form, giving a relevant reference.
• 1. Total of listed share capital

The total listed share capital of each company listed on the CSE as at the last working day of every quarter (end of March, June, September, December).

1. Buy Back:

The total number of shares which were acquired by the company itself, including shares which the company owned previously and which are kept in a portfolio and the shares which were acquired by a person acting in his name but ob behalf of the company. Companies Law, 135(I)/ 2000.

1. Company Employees

The total number of shares that the personnel owns to the listed share capital of the company shall be submitted to the Council. The Council shall examine each case separately and will decide as to whether this percentage should be considered as free float to the public.

Specifically where there is a large number of employees of the company with the largest stake in its share capital shall be stated, as well as the total number of shares held by the remaining employees. The total number of employees of the company should also be stated.

14. Trading Code / Trading Account

Refers to all the trading codes/references and Trading Accounts linked to the persons which are referred to in Sections A and B of the comprehensive free - float form. If there is no trading code/reference, the identification number or the registration number of the company should be stated.

15. Companies financing investment schemes

Where the abovementioned companies possess a percentage greater than or equal to 5% of the listed share capital of a listed company, an analytical statement of the shareholders, the number of shares they hold, as their percentage to the total share capital of the company should be stated in part B.

1. Comprehensive details concerning the free - float of the share capital of the company:.

2. · In part A the Market in which the shares of the company are traded should be stated.

3. · In part B the following details should be given:
   • (i) The number of legal and natural persons of the company. In this number, the information given in Parts B4 and B5 shall not be taken into account, in order to avoid double counting.
   • (ii) In part B the following should be stated:
     • a. The number of the Members of the Board who hold shares.
     • b. The number of persons who hold shares in their name but on behalf of all of the Members of the Board.
     • c. The number of persons who hold shares through undertakings controlled by the Members of the Board.
     • d. The number of persons who act in concert with the Members of the Board.
   • (iii) In part B5 the number of major shareholders possessing over 5% of the share capital should be stated. Note that if the major shareholder is a Member of the Board or a company that has been included in part B4, then it should not be included for second time.