Directors' Dealings

Securities transactions subject to disclosure (directors’ dealings)

Pursuant to Section 15a of the German Securities Trading Act (WpHG), the members of the Board of Management and the members of the Supervisory Board of SMARTRAC N.V. are obliged to disclose all of their transactions in SMARTRAC shares that exceed the amount of EUR 5,000. The disclosure obligation also applies to:

• Persons who perform management functions at SMARTRAC N.V. and regularly have access to insider information or who are authorised to make important business decisions;
• Persons who are in a close relationship to the aforementioned groups of persons (e.g. spouses, registered partners, as well as legal entities for which the aforementioned persons perform management duties and legal entities, companies and institutions which are directly or indirectly controlled by persons subject to these disclosure obligations).

Disclosure of transactions by persons with management functions pursuant to Section 15a of the German Securities Trading Act (WpHG)