Ze Pak S.A. — Major Shareholding Notification 2025

Sep 27, 2025

Solkomtel Foundation, Vaduz

Industriering 14, 9491 Ruggell

23 September 2025

To: ZE PAK S.A. ul. Kazimierska 45 62-510 Konin, Poland

Via e-mail to:

Janiszowski.Andrzej@zepak.com.pl nietopiel.maciej@zepak.com.pl

Dear Sirs,

Acting on behalf of the Solkomtel Foundation, with its registered address at c/o BlueRidge Management AG, Industriering 14, LI-9491 Ruggell, and registration number FL-0002.419.785-2 (the "Foundation"), and with reference to the letter received from Stasalco Limited on 15 September 2025, concerning the parent undertaking of the Foundation, and in connection with the letter sent by ZE PAK S.A. to Elektrim S.A. and letter sent by Elektrim S.A. to Stasalco Limited, we hereby provide the following information.

Based on the definition provided in Article 4(14) of the Polish Public Offerings Act, we hereby Inform you that the Foundation does not have a parent undertaking. Specifically, there is no entity that:

• 1. directly or indirectly holds the majority of votes in the Foundation's governing body (the Foundation Board), or
• 1. has the authority to appoint or remove the majority of the Foundation Board members, or
• 1. more than half of the members of the management board of such another entity are also members of the Foundation Board, proxies or persons performing managerial functions in the Foundation, or persons in managerlal positions within the parent or its subsidiarles,

The Foundation does not have a management or supervisory board. Its governing body is the Foundation Board, which is responsible for managing the Foundation's affairs and representation. The current members of the Foundation Board are:

• 1. Peter Schierscher appointed by the Princely Court in Vaduz, Liechtenstein;
• 1. Jarosław Grzesiak appointed jointly by Tobias Solorz, Aleksandra Żak and Piotr Żak;
• 1. Tomasz Szelag appointed by Zygmunt Solorz.

The Foundation is represented jointly by Peter Schierscher acting together with either Tomasz Szeląg or Jarosław Grzesiak.

The register of beneficial owners of the Foundation sets out:

• 1. Zygmunt Solorz as founder, curator and first beneficiary (the sole economic beneficiary of the Foundation for life);
• 1. Peter Schierscher as Foundation Board member;
• 1. Jarosław Grzesiak as Foundation Board member;
• 1. Tomasz Szelag as Foundation Board member.

Please find enclosed a copy of the extract from the Foundation's register of beneficial owners, confirming the status and relevant personal details of the individuals listed above,

Furthermore, in connection with the questions addressed in the Foundation, the Foundation wishes to present a detailed ownership structure for the companies that submitted questions, for the purpose of assessing dependencies within the group:

• 1) the Foundation holds 100% of the shares in Stasalco Limited,
• 2) Stasalco Limited holds 71,450,393 shares in Elektrim S.A. (85,29% of shares and votes at the general meeting of the company),
• 3) Elektrim S.A. holds 100% of the shares in Anokymma Limited and Enelka Taahhüt Imalat ve Ticaret AS.
• 4) Anokymma Limited and Enelka Taahhüt Imalat ve Ticaret AS together hold 100% certificates in IB8 FIZAN,
• 5) IB8 FIZAN holds 100% of the shares in Polynon Investments Limited, Progoria Investments Limited, Justiana Investments Limited, Iceneus Investments Limited,
• 6) the companies indicated below hold shares in Argumenol Investment Company Limited in the following percentages: Elektrim S.A. - 11.5%, Anokymma Limited - 12.64%, IB8 FIZAN -51.4%, Polynon Investments Limited - 3.67%, Progoria Investments Limited - 7.34%, Justiana Investments Limited - 4.89%, Iceneus Investments Limited - 8.56%,
• 7) Argumenol Investment Company Limited holds 33,523,911 shares in ZE PAK S.A. (65,96% of shares and votes at the general meeting of the company).

At the same time, we kindly ask the Management Board of ZE PAK S.A. to immediately forward this correspondence to all companies controlled by ZE PAK S.A. supplemented by the ownership structure of companies controlled by ZE PAK S.A. (both directly and indirectly).

For the Foundation:

Dr. Peter Schierscher Chairman of the Foundation Board

Tomasz Szelag Member of the Foundation Board

Jarosław Grzesiak Member of the Foundation Board

Appendices:

• extract from the register of the beneficial owners of the Foundation
• extract from the foundation register of the Foundation