Granolio d.d.

Transaction in Own Shares • Oct 30, 2025

Granolio d.d.

Ulica Pere Budmanija 5, HR-10000 Zagreb,
tel: +385 1 6320 200, faks: +385 1 6320 222, e-mail: granolio@granolio.hr, www.granolio.hr

Hrvatska agencija za nadzor financijskih usluga (HANFA) Službeni registar propisanih informacija Franje Račkoga 6 10000 ZAGREB

Zagrebačka burza d.d. Ivana Lučića 2a 10000 ZAGREB

HINA – Hrvatska izvještajna novinska agencija ots@hina.hr

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, October 30, 2025

Subject: Notice of the held Session of the Management Board – Share Buyback Program - Other prescribed information

Pursuant to the Capital Market Act and the Zagreb Stock Exchange Rules, GRANOLIO d.d., Zagreb, Ulica Pere Budmanija 5, Personal Identification Number (PIN): 59064993527, a company entered into the Court register of the Commercial Court in Zagreb under the identification number (MBS) 080111595 (hereinafter: the Company), hereby announces that on October 30, 2025 the Management Board of the Company held its Session at which, with the approval of the Supervisory Bord, the Share Buyback Program was adopted, in accordance with the Decision of the General Assembly dated July 18, 2025, as attached to this Notice.

This notification was delivered to the Officially appointed mechanism for the central storage of regulated information of the Croatian Financial Services Supervisory Agency – HANFA, Zagreb Stock Exchange, Croatian News Agency - HinaOTS and it is available on the Company web site www.granolio.hr.

GRANOLIO d.d.

The Management Board of Granolio d.d., Zagreb, Ulica Pere Budmanija 5, OIB 59064993527 (hereinafter referred to as the "Company" or "Issuer"), based on the Decision on granting the Management Board the authority to acquire treasury shares and the Decision on the exclusion of the pre-emptive rights of existing shareholders, adopted at the General Assembly of the Company on 18.07.2025, and in accordance with the provisions of the Capital Market Act (Official Gazette No. 65/2018, 17/2020, 83/2021, 151/2022, 85/2024) and the Ordinance on the conditions for implementing the treasury share buyback program and financial instrument stabilization measures under which exemption from the prohibition of market abuse is achieved (Official Gazette No. 5/2009, 65/2018; hereinafter referred to as the "Ordinance"), at the Management Board session on 30.10.2025. adopts the following

PROGRAM OF TREASURY SHARES BUYBACK

INTRODUCTORY PROVISIONS

Article 1.

On July 18, 2025, the General Assembly of the Company was held, at which, among other things, the Decision on granting the Company's Management Board the authority to acquire its own shares and the Decision on the exclusion of the pre-emptive rights of existing shareholders were adopted.

Article 2.

The decision authorizing the Company's Management Board to acquire its own shares authorizes the Company's Management Board to acquire its own shares for a period of 5 (five) years from the date of the same decision, during which the Company's Management Board is authorized, based on the aforementioned decision and without further special approvals from the Company's General Assembly, to acquire the Company's own shares with the symbol GRNL-R-A in the name and for the account of the Company, under the following conditions:

• 1) shares acquired based on the aforementioned decision, together with the Company's own shares already held by the Company, may not account for more than 10% (ten percent) of the Company's share capital;
• 2) The Company's Management Board must acquire its own shares on an organized securities market;
• 3) the price at which the Company's own shares are purchased may not be above 10% (ten percent), or below 10% (ten percent) of the average market price achieved for those shares in the previous 30 (thirty) days. If such data does not exist for the period of the previous 30 (thirty) days, then the price at which treasury shares are purchased must not be above 10% (ten percent), or below 10% (ten percent) of the average market price achieved for those shares in the previous 90 (ninety) days;
• 4) in the business year in which the Company acquired its own shares, it must enter a part of the profit in the reserves for those shares in that year and state the amounts corresponding to the amounts paid for the acquisition of its own shares, so that the net

assets of the Company stated in the financial statements for the last business year due to the acquisition of shares do not become less than the amount of share capital and reserves that the Company must have by law or by the statute or by decision of the General Assembly of the Company, and which may not be used for payments to shareholders;

• 5) the Company may not trade with the acquired own shares;
• 6) The Management Board of the Company is authorized to acquire its own shares for the purpose of disposal within the framework of the remuneration program for members of the Management Board and key employees of the Company. For the acquisition of its own shares for other purposes, the Management Board of the Company must obtain the prior consent of the Supervisory Board of the Company.
• 7) The Management Board of the Company must report to the first subsequent General Assembly of the Company on the reasons and purpose of the acquisition of shares, their number and share in the share capital, and the equivalent value of what the Company gave for those shares. The Management Board of the Company has the same obligation towards the Supervisory Board of the Company, provided that the report must be submitted to the Supervisory Board within one month of the end of each individual quarterly period.

The Company's Management Board is obliged to adopt a program for the disposal of its own shares, for which it is necessary to obtain the prior consent of the Company's Supervisory Board.

The Company's Management Board is authorized, with the prior consent of the Company's Supervisory Board, to dispose of its own shares, which it already holds or will acquire based on the aforementioned decision, also outside the organized market (for example, by disposal within the framework of the remuneration program for members of the Company's Management Board), and for this, apart from the aforementioned decision, no special decision of the Company's General Assembly is required.

Article 3.

By adopting the Decision on the Exclusion of Pre-emptive Rights, the Management Board is authorized, with previous Supervisory Board approval, to dispose of treasury shares which are already held or will be acquired based on the decision referred to in Article 2 of this program, and outside the organized market (for example, by disposal within the framework of the remuneration program for members of the Company's Management Board), and for which, apart from the decision referred to in Article 2 of this program, no special decision of the General Assembly of the Company is required, whereby the decision referred to in this Article of this program excludes the pre-emptive right of existing shareholders.

PURPOSE OF THE PROGRAM

Article 4.

This program regulates the terms and conditions of the repurchase of own shares in accordance with the aforementioned decisions of the General Assembly of the Company.

The goal of this program is to fulfill the obligations arising from the reward program for members of the Management Board and key employees of the Company.

The program will be implemented in accordance with the provisions of the Companies Act.

The Company plans to repurchase its own shares on the regulated market of the Zagreb Stock Exchange d.d. The implementation of the repurchase program of own shares depends on market conditions and strategic decisions of the Company and may be changed, abandoned or adjusted in any way during the stipulated terms of its duration

PROGRAM TERMS

Article 5.

The maximum number of treasury shares that the Company may purchase under this program is 189,664 shares.

The total compensation that the Company is willing to pay as a countervalue for the specified quantity of treasury shares may amount to a maximum of EUR 5,689,920.00 (five million six hundred eighty-nine thousand nine hundred and twenty euros).

The Company will purchase Shares through the trading system of the Zagreb Stock Exchange d.d. or through over-the-counter (OTC) transactions on a regulated market.

In accordance with the decision of the General Assembly of the Company, the Management Board of the Company is authorized to purchase up to 10% of the Company's share capital, together with treasury shares that the Company already holds. The price at which treasury shares are purchased may not be above 10%, or below 10% of the average market price achieved for those shares in the previous 30 (thirty) days. If such data does not exist for the period of the previous 30 (thirty) days, then the price at which the company's own shares are purchased must not be above 10% (ten percent), or below 10% (ten percent) of the average market price achieved for those shares in the previous 90 (ninety) days;.

The share buyback program will begin on November 1, 2025 and will be completed no later than July 18, 2030. The Company is not obligated to buy back its own shares at any time, but will act as a buyer depending on market conditions.

In the business year in which the Company acquires its own shares, it must enter a portion of the profit in that year into the reserves for those shares and report amounts corresponding to the amounts paid for the acquisition of its own shares, so that the Company's net assets reported in the financial statements for the last business year due to the acquisition of shares do not become less than the amount of share capital and reserves that the Company must have by law or by the statute or by decision of the General Meeting of the Company, and which may not be used for payments to shareholders.

The Management Board of the Company will report to the first subsequent General Meeting of the Company on the reasons and purpose of the acquisition of shares, their number and share in the share capital, and on the equivalent value of what the Company gave for those shares. The Company's Management Board will also report the same to

the Company's Supervisory Board within one month of the end of each individual quarterly period.

PURCHASE CONDITIONS

Article 6

During the implementation of this program, the price at which the Issuer's own shares will be acquired and the daily volume will not exceed the limits prescribed in Article 5 of the Ordinance on the conditions for implementing the share buyback program and financial instrument stabilization measures under which exemption from the prohibition of market abuse is achieved (Official Gazette No. 5/2009, 65/2018), or other relevant regulation.

PUBLICATION

Article 7.

The Company shall report each transaction under this program to the Croatian Financial Services Supervisory Agency and the Zagreb Stock Exchange. The aforementioned reports shall contain information on each transaction carried out under this program, including information on the shares purchased, the total number of shares purchased, the date and time of each transaction, the price of the transaction, and information on the investment companies or credit institutions that mediated the transactions.

The Company shall publish details of all transactions referred to in the previous paragraph no later than 7 (seven) trading days from the date of each transaction, on the Company's website (www.granolio.hr).

FINAL PROVISIONS

Article 8.

All amendments and supplements to this program shall be adopted by the Company's Management Board, and the Company shall promptly notify the Croatian Financial Services Supervisory Agency and the Zagreb Stock Exchange of such amendments and supplements.

Granolio d.d.