The Management Board of Apator S.A. hereby announces that its subsidiary Apator Metrix S.A. with its registered office in Tczew (the ‘Company’) has today received a decision dated 25 September 2025 on the initiation of antitrust proceedings by the President of the Office of Competition and Consumer Protection against the Company in connection with a suspected agreement within the meaning of Article 4(5) of the Act on Competition and Consumer Protection (‘Act’) and an agreement or concerted practice within the meaning of Article 101 sec. 1 of the Treaty on the Functioning of the EU, consisting in:

• market sharing in relation to bellows gas meters, which may constitute a violation of Article 6 sec. 1 point 3 of the Act and Article 101 sec. 1 point c) of the Treaty on the Functioning of the EU (the ‘Treaty’),
• agreeing on the terms and conditions of bids submitted in tenders for the supply of bellows gas meters organised by Polska Spółka Gazownictwa sp. z o.o. with its registered office in Tarnów, which may constitute a violation of Article 6 sec. 1 point 7 of the Act.

The proceedings concern public tenders organised in 2014-2021. Pursuant to Article 106 sec. 1 point 1 and 2 of the Act, the President of the Office of Competition and Consumer Protection may, by way of a decision, impose on an entrepreneur a financial penalty of up to 10% of the turnover achieved in the financial year preceding the year in which the penalty was imposed, if the entrepreneur, even unintentionally, violated the prohibition specified in Article 6 of the Act or violated Article 101 of the Treaty. At the same time, pursuant to Article 106 sec. 3a of the Act, when calculating turnover, the President of the Office of Competition and Consumer Protection also takes into account the turnover achieved by the entrepreneur or entrepreneurs exercising decisive influence on the entrepreneur who committed the infringement of the prohibition specified in Article 6 of the Act or Article 101 of the Treaty. Pursuant to Article 111 sec. 1 of the Act, when determining the amount of the financial penalty, the following factors shall be taken into account, among others: the duration, degree and market effects of the infringement of the provisions of the Act, the circumstances of the infringement and any previous infringements of the provisions of the Act.

The Company will present a substantive defence in the course of the proceedings. As at the date of publication of this report, the Management Board of the Company and the Management Board of Apator S.A. do not have sufficient data to estimate the outcome of the proceedings or the potential impact of these proceedings on the financial results of the Company or Apator S.A.