Shelly Group SE

Audit Report / Information • Jun 29, 2022

To the shareholders of Allterco JSCo Sofia

DECLARATION

Under Article 100n (4)(3) of the Public Offering of Securities Act

We, the undersigned:

1. Iliya Nedelchev Iliev, in my capacity as a general manager of Primorska Audit Company OOD with Company's Id. No. 103599983, with seat, registered address and contact address: Varna, General Kolev St. No. 104, floor 5, apartment 32,

2. Marian Vasilev Nikolov, in my capacity as a registered auditor with Registration No. 0601 in the register with CPOSA under Article 20 of the Independent Financial Audit Act, responsible for the audit engagement on behalf of Primorska Audit Company OOD - audit company with Registration No. 086 in the register with CPOSA under Article 20 of the Independent Financial Audit Act, declare that:

Primorska Audit Company Ltd. was committed to perform a statutory financial audit of the separate financial statements of Allterco JSCo. for 2021, prepared in in accordance with the International Accounting Standards adopted by the EU, a generally accepted accounting bases defined in item 8 of the Additional provisions of the Accountancy Act under the name "International Accounting Standards". As a result of our audit, we issued an audit report dated March 25, 2022.

We hereby CERTIFY that as reported in the audit report issued by us on the separate financial statements of Alterco Jsc. for 2021, dated March 25, 2022:

1. Art. 100n, para. 4, item 3(a) Auditor's opinion: In our opinion, the separate annual financial statements present, in all material respects, the financial position of the Company as of December 31, 2021, and its financial performance and cash flows for year than ended, in accordance with the International Accounting Standards (IAS) adopted for implementation by the European Union (EU).

2.Article 100n(4) (3b) Information regarding the related parties transactions of Allterco JSCo. The information regarding transactions with related parties has been duly disclosed in Notes 6 and 7 to the separate financial statements. Based on the audit procedures performed by us on the transactions with related parties as a part of our general audit of the financial statements, we have not become aware of any facts, circumstances or other information based on which we could conclude that the transactions with related parties have not been disclosed in the enclosed separate financial statements for the year ended December 31, 2021 in any material aspects in accordance with the requirements of IAS 24 Related Party Disclosures.

The results from our audit procedures on the related parties' transactions have been reviewed by us in the context of forming our opinion about the financial statements, not for the purpose of expressing a separate opinion on the related party transactions.

3. Article 100n (4) (3c) Information regarding significant transactions. Our responsibility for the audit of the financial statements, as described in the section of our report called Auditor's Responsibility for the Audit of Financial Statements, include an assessment of whether the financial statements present the significant transactions and events in a manner which achieves faithful representation. Based on the audit procedures carried out by us in relation to significant transactions of fundamental importance for the financial statements for the year ended December 31, 2021, we have not become aware of facts, circumstances or other information based on which we could conclude that there are instances of material unreliable presentation and disclosure in accordance with the applicable IAS requirements adopted by the EU. The results from our audit procedures on the Company's transactions and events which are of material significance to the financial statements have been reviewed by us in the context of forming our opinion about the financial statements, not with the purpose of expressing a separate opinion on these significant transactions.

The certifications made in this Declaration should be viewed only and solely in the context of the auditor's report issued by us as a result of the independent financial audit of the separate annual financial statements of Allterco JSCo. dated March25, 2022, for the reporting period ended December 31, 2021. This Declaration is intended only for the above-mentioned addressee and it has been prepared only and solely in accordance with the requirements set out in Article 100n(4)(3) of the Public Offering of Securities Act (POOSA) and should not be viewed as a replacement of our conclusions given in the auditor's report compiled by us as at March 25, 2022 regarding the matters covered by Article 100n(4)(3) of the POOSA.

Audit company Priorska Audit Company Ltd. Registration № 086

Iliya Iliev General manager Nedelchev Iliev

Digitally signed by Iliya Nedelchev Iliev Date: 2022.03.25 21:18:40 +02'00'

March 25, 2022

Marian Nikolov Registered auditor, responsible for the audit Registration 0601

MARIAN VASILEV NIKOLOV Digitally signed by MARIAN VASILEV NIKOLOV Date: 2022.03.25 20:43:53 +02'00' Iliya