MIDI Plc

Legal Proceedings Report • Jun 25, 2025

Company Announcement

The following is a Company Announcement issued by MIDI p.l.c. ("MIDI" or the "Company") pursuant to the Capital Markets Rules of the Malta Financial Services Authority ("MFSA").

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Clarification on Recent Media Coverage and Project Timeline

MIDI plc wishes to address the recent article published in Malta Today on June 25, 2025 entitled "Have the retail investors in MIDI plc been treated well?", which refers to the bond prospectus issued by the Company in June 2016. This announcement is being issued to address the speculative nature of the article in question.

The article specifically references the "Risk Factors" section of the prospectus which refer to Article 8.1.4 of the Deed of Emphyteusis, which sets the substantial completion date for the Tigné Point and Manoel Island projects as March 2023.

The articulation of risk factors in a prospectus is a regulatory requirement ensuring transparency without the inclusion of mitigating factors. This practice does not imply the absence of such factors; rather, it ensures that investors are fully informed of potential risks.

Contrary to the speculative narrative presented in the article, the Deed of Emphyteusis, which was a document available for inspection as part of the Prospectus (section 18 of the Registration Document, forming part of the Prospectus), provides a comprehensive framework for automatic extensions of the completion date due to delays in the issue of permits beyond 3 months (Article 13); delays associated with events or circumstances outside the company's control (Article 17); and delays associated with archaeological discoveries (Article 16).

The article in question highlights only one of a number of delays encountered by the Company, namely the FAA's appeal with respect to the Outline Development Permit approved in March 2019. At that time the Company was already suffering delays due to the archaeological discoveries, including as a result of the investigations undertaken under the supervision of the Superintendence of Cultural Heritage (SCH) spanning from 2017 to 2022. The outcome of these investigations resulted in the SCH directing MIDI to revise its plans for the development of Manoel Island in 2022 to ensure that no development and construction takes place on the impacted area measuring approximately 22,000sqm. Further delays arose from the FAA's appeal to the revised EIA approved in June 2021, which was resolved in May 2023 when the Court of Appeal rejected the appeal, and the ongoing Heritage Impact Assessment process initiated in March 2024.

The Company contends that a correct interpretation of the Deed grants MIDI an automatic extension to the substantial completion date of at least 10 years to compensate for these delays as well as the delays experienced pre 2013 related to the Garden Battery at Tigne Point, which directly impacted the company's ability to progress with the development of Manoel Island. Indeed, the substantial completion date continues to be automatically extended by the period starting from 3 months from the application date until the final development permit for Manoel Island is definitively issued and all conditions beyond the Company's control satisfied.

At the recent AGM of the Company the various delays giving rise to the automatic extension were explained to shareholders (refer to: https://www.midimalta.com/loadfile/c3a7b5aa-00ea-4f64-8d76-a37c1a47d58c )

Furthermore, references in the article to MIDI's financial statements are misleading. Indeed, the Company highlighted on several occasions in its financial statements that the substantial completion date is subject to an extension in the eventuality of delays which result from events or circumstances outside the Company's control or as a result of delay in the issue of permits. It further highlighted that the Company has experienced a number of delays associated with the issue of building permits and encountered site related conditions which were unknown at the point in time when the Emphyteutical concession was granted. The Board also declared that the company was actively engaged in discussion with Government and the Board was, at that time, confident that the successful completion of the project would be achieved.

MIDI is committed to clarifying public information and addressing any factual misrepresentations.

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Catherine Formosa Company Secretary

25th June 2025