Sopharma AD

Director's Dealing • Dec 22, 2025

Current report: №265/22.12.2025 NOTIFICATION OF INSIDERS' TRANSACTIONS under art. 19 of Regulation 596/2014

Dated: 22.12.2025

a) Name Donev Investments Holding AD [For physical persons: the first name and the last name(s).] [For legal persons: full name including legal form as provided for in the register where it is incorporated, if applicable.] 2. Reason for the notification a) Position/status Based on the provisions of art.3, para 1, item 26, letter "g" of Regulation 596/2014 as a person closely associated. Ognian Donev is an Executive director and chairman of the Board of directors of Sopharma AD and chairman of the Board of directors of Donev Investments Holding AD [For persons discharging managerial responsibilities: the position occupied within the issuer, emission allowances market participant/auction platform/auctioneer/auction monitor should be indicated, e.g. CEO, CFO.] [For persons closely associated, -An indication that the notification concerns a person closely associated with a person discharging managerial responsibilities; - Name and position of the relevant person discharging managerial responsibilities.] b) Initial notification/ Initial notification Amendment [Indication that this is an initial notification or an amendment to prior notifications. In case of amendment, explain the error that this notification is amending.] Details of the issuer, emission allowance market participant, auction platform, auctioneer or auction monitor Sopharma AD a) Name [Full name of the entity.] b) LEI 097900BGGW0000048796 [Legal Entity Identifier code in accordance with ISO 17442 LEI code.] 4. 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 Shares, ISIN № BG11SOSOBT18 instrument, type of Indication as to the nature of the instrument instrument Identification — a share, a debt instrument, a derivative or a financial instrument linked to a share or a code debt instrument; — an emission allowance, an auction product based on an emission allowance or a derivative relating to an emission allowance. Instrument identification code as defined under Commission Delegated Regulation supplementing Regulation (EU) No 600/2014 of the European Parliament and of the Council with regard to regulatory technical standards 600/2014. b) Nature of the transaction Buy [Description of the transaction type using, where applicable, the type of transaction identified in Article 10 of the Commission Delegated Regulation (EU) 2016/522 (1) adopted under Article 19(14) of Regulation (EU) No 596/2014 or a specific example set out in Article 19(7) of Regulation (EU) No 596/2014. Pursuant to Article 19(6)(e) of Regulation (EU) No 596/2014, it shall be indicated whether the transaction is linked to the exercise of a share option programme.] c) Price(s) and volume(s) Price(s) volume(s) 2.78 2.79	1.	Details of the person discharging managerial responsibilities/person closely associated
	3.
		for the reporting of transactions to competent authorities adopted under Article 26 of Regulation (EU) No
		38.00
		212.00

Current report: №265/22.12.2025 NOTIFICATION OF INSIDERS' TRANSACTIONS under art. 19 of Regulation 596/2014

Dated: 22.12.2025

		[Where more than one transaction of the same nature (purchases, sales, lendings, borrows, …) on the same financial instrument or emission allowance are executed on the same day and on the same place of transaction, prices and volumes of these transactions shall be reported in this field, in a two columns form as presented above, inserting as many lines as needed.
		Using the data standards for price and quantity, including where applicable the price currency and the quantity currency, as defined under Commission Delegated Regulation supplementing Regulation (EU) No 600/2014 of
		the European Parliament and of the Council with regard to regulatory technical standards for the reporting of
		transactions to competent authorities adopted under Article 26 of Regulation (EU) No 600/2014.]
d)	Aggregated information	Price volume
		2.79 250
		[The volumes of multiple transactions are aggregated when these transactions:
	— Aggregated volume —	— relate to the same financial instrument or emission allowance;
	Price	— are of the same nature;
		— are executed on the same day; and
		— are executed on the same place of transaction.
		Using the data standard for quantity, including where applicable the quantity currency, as defined under
		[Price information:
		— In case of a single transaction, the price of the single transaction;
		— In case the volumes of multiple transactions are aggregated: the weighted average price of the aggregated
		Using the data standard for price, including where applicable the price currency, as defined under Commission
e)	Date of the transaction	19.12.2025
		[Date of the particular day of execution of the notified transaction.
		Using the ISO 8601 date format: YYYY-MM-DD; UTC time.]
f)	Place of the transaction	BSE AD
		[Name and code to identify the MiFID trading venue, the systematic internaliser or the organised trading if the transaction was not executed on any of the above mentioned venues, please mention 'outside a trading

venue'.]