Current Report No. 9/2022

01.03.2022

Subject: Notification of initiation of administrative proceedings by the KNF

Legal basis: Article 17(1) MAR – confidential information

The Management Board of ManyDev Studio SE (the “Company”, “Issuer”) hereby announces that today, i.e. 28 February 2022 The Company has received from the Financial Supervision Authority (“KNF”) a decision to initiate ex officio administrative proceedings to impose administrative penalties on the Company pursuant to:

(a) Article 96 (1e) of the Act on Public Offering, Conditions Governing the Introduction of Financial Instruments to Organised Trading, and Public Companies of 29 July 2005 (Journal of Laws 2021, item 1983, as amended, hereinafter the “Act on Offering”), in the wording in force prior to the entry into force of the Act of 10 February 2017 amending the Act on Trading in Financial Instruments and certain other acts (Journal of Laws 2017, item 724, hereinafter: “Amendment Act No. 1”) or Article 96 (1f) of the Act on Offering, in connection with a suspected breach of Article 56(1) point 2b of the Act on Offering, in the wording in force prior to the entry into force of the Act of 9 March 2017 amending the Act on Trading in Financial Instruments and certain other acts (Journal of Laws 2017, item 791, hereinafter: “Amendment Act No. 2”) in connection with the preparation of the annual report for the 2016 financial year published on 31 March 2017.

and

(b) Article 96 (1e) of the Public Offering Act, as amended by Amendment Act No. 1, or Article 96 (1f) of the Public Offering Act, in connection with a suspected breach of Article 56 (1) point 2b of the Public Offering Act, as amended by Amendment Act No. 2, in connection with the annual report for the 2017 financial year published on 30 April 2018.

At the same time, the Company informs that the KNF has not provided a justification for the aforementioned decision. The events cited as the basis for the initiation of the proceedings took place prior to the conclusion of the investment agreement dated 1 February 2021.