Trakcja S.A.

Notification on the transaction indicated in Article 19.1 of MAR

11	Datails of the person discharging managerial responsibilities/person closely associated
a)	Name	COMSA, S.A.U.
2	Reason for the notification
	a) Position/status	PERSON CLOSELY ASSOCIATED WITH FERNANDO PEREA SAMARRA, MIQUEL LLEVAT VALLESPINOSA AND JORGE MIARNAU MONTSERRAT, MEMBERS OF THE SUPERVISORY BOARD OF THE ISSUER
	b) Initial notification/amendment	INITIAL NOTIFICATION
	3 Details of the issuer, emission allowance auction monitor	market participant, auction platform, auctioneer or
	a) Name	TRAKCJA S.A.
	b) LEI	259400IOJQXO1TS70C40
		4.1 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a)	Description of the financial instrument, type of instrument Identification code	DEMATIONAL PRODUCT BE REPOSITION SHARES ISIN: PLTRKPL00014
b)	Nature of the transaction	ESTABLISHMENT OF REGISTERED AND FINANCIAL PLEDGES OVER SHARES
C)	Price and volume	Price	Volume
d)	Aggregated information Aggregated volume	PLN 2.13 In case of exercising the rights under the pledge, the value of the acquired shares shall be determined at the quotation rate at the end of the acquisition day. If the shares were not quoted on that day, the value shall be determined at the price of the last day of their quotation.	16,156,193
	- Price		16,156,193 PLN 2.13
e)	Date of the transaction	31.12.2020

11/1

		4.2 Details of the transaction(s): section to be repeated for (i) each type of instrument; (ii) each type of transaction; (iii) each date; and (iv) each place where transactions have been conducted
a)	Description of the financial instrument, type of instrument	RECISTERED SHARES
b)	Nature of the transaction	ESTABLISHMENT OF REGISTERED AND FINANCIAL PLEDGES OVER SHARES
C)	Price and volume	Price	Volume
		PLN 2.13 In case of exercising the rights under the pledge, the value of the acquired shares shall be determined at the quotation rate at the end of the acquisition day. If the shares were not quoted on that day, the value shall be determined at the price of the last day of their aniatation	12,242,952
d)	Aggregated information Aggregated volume - Price	12,242,952 PLN 2.13
e)	Date of the transaction	31.12.2020
f)	Place of the transaction	OUTSIDE A TRADING VENUE
		On behalf of COMSA, S.A.U.
		Paulina Galewska - Proxy