Current report No. 5/2022

04.02.2022

Topic: Discontinuation of administrative proceedings before Polish Financial Supervision Authority

Legal basis: Art. 17 sec. 1 of MAR – confidential information.

With reference to current reports No. 17/2021 and 39/2021, ManyDev Studio SE (“Company”, “Issuer”) hereby informs that today, i.e. February 4, 2022, it received from the Polish Financial Supervision Authority (“KNF”) a decision on the entire discontinuation of administrative proceedings by the KNF regarding the imposition of administrative penalties on the Issuer on the basis of:

1) art. 96 sec. 1 point 1 and art. 96 section 1e of the Act of July 29, 2005 on Public Offering, Conditions Governing the Introduction of Financial Instruments to Organized Trading and Public Companies (Journal of Laws of 2020, item 2080, as amended, hereinafter: “Act on Public Offering”) and 96 sec. 1f of the Act on Offer, in connection with the suspected violation of art. 56 sec. 1 point 2 lit. a of the Act on Public Offering in connection with the preparation of the annual report for the financial year 2016 published on March 31, 2017.

2) art. 96 sec. 1 point 1 and art. 96 sec. 1e of the Act on Offer and art. 96 sec. 1f of the Act on Offer, in connection with the suspected violation of art. 56 sec. 1 point 2 lit. a of the Act on Public Offering in connection with the preparation of the annual report for the financial year 2017 published on April 30, 2018.

In accordance with the justification of the decision, the KNF discontinued the proceedings as redundant due to the fact that the proceedings were initiated in connection with the suspected violation of art. 56 sec. 1 point 2 lit. a of the Act on Offer. The Issuer is not an issuer of securities admitted to trading on a regulated market and was not obliged to fulfill the disclosure obligations in accordance with the principles adopted in art. 56 sec. 1 point 2 lit. a of the Act on Offer. As the Issuer whose shares were admitted on the parallel market, the Company was obliged to fulfill the information obligations related to the publication of the report for 2016 and 2017 in accordance with art. 56 sec. 1 point 2 lit. b of the Act on Offer.