Pursuant to the Euronext Growth Milan Issuer Regulation, those who participate in the share capital of I.CO.P. S.p.A. Società Benefit (the “Issuer”) must notify any “substantial change,” or the reaching or exceeding of thresholds of 5%, 10%, 15%, 20%, 25%, 30%, 50%, 66.6%, and 90% of the Issuer’s share capital, as well as any reduction below these thresholds (the “Substantial Change”). In the case of the issuance of multiple voting shares, even a shareholder holding 5% based on ordinary shares must report. Additionally, in the case of the issuance of multiple voting shares, for the purposes of fulfilling disclosure obligations, the share capital refers to both the total number of voting rights and the number of ordinary shares held, and both disclosures are required.

For the calculation of the holdings of a so-called significant shareholder—who holds at least 5% or more in a category of Euronext Growth Milan shares (excluding treasury shares) according to the regime for significant holdings under the Consolidated Finance Act—the following must be included: i) the holdings the shareholder holds (even if the voting rights are granted or assigned to third parties); ii) the holdings with respect to which the voting rights are granted or assigned; iii) shares held by intermediaries, fiduciaries, controlled companies, or for which the voting rights are granted or assigned to such entities; and iv) shares collectively contributed to a shareholder agreement concerning the exercise of voting rights in the Issuer.

For the purposes outlined above, the significant shareholder must promptly notify the Issuer, and in any case within 4 trading days of the transaction that triggers the obligation (regardless of the execution date) or from the day the shareholder became aware of events affecting the Issuer’s share capital, providing the following information:

• Their identity;
• The date when the Issuer was informed;
• The date when the Substantial Change in holdings occurred;
• The nature and extent of the significant shareholder’s participation in the transaction (in the case of the issuance of multiple voting shares, the number of voting rights and the number of ordinary shares held).

The notification must be made using the attached form, which should be sent via PEC to the following address: icop.ud00@infopec.cassaedile.it and, for information, to ir@icop.it.