Rules for Primary Insiders

In addition to the duties and responsibilities that are incumbent on each B2Holding employee and member of the Board of Directors, Primary Insiders are subject to special duties and responsibilities which are described in these rules.

RULES FOR PRIMARY INSIDERS

Adopted by the Board of Directors on 15 February 2016 and revised 3 March 2021 and reaffirmed on 16 September 2021.

The purpose of these rules (“Rules”) is to provide some guidance on who qualifies as a Primary Insider or as Primary Insider’s Related Party and what are the rules and procedures applicable for such persons, and liabilities in case of non-compliance therewith.