MANAGERS´ TRANSACTIONS

Article 15a of the German Securities Trading Act (Wertpapierhandelsgesetz/WpHG) requires members of the Klöckner & Co SE Management Board and Supervisory Board to notify the company and the German Federal Financial Services Supervisory Authority (BaFin) within five working days of their transactions involving Klöckner & Co shares and related financial instruments, particularly derivatives, if such dealings exceed a total of EUR 5,000 before the end of the calendar year.

The mandatory disclosure requirement also applies to

• Persons performing management duties for Klöckner & Co SE who regularly have access to insider information and are authorized to make material corporate decisions; and
   
• Persons closely associated with the aforementioned groups of persons (including spouses, registered civil partners, dependent children and relatives living in the same household as the aforementioned persons for at least one year, as well as legal entities for which the aforementioned persons perform management duties and legal entities, companies and institutions that are directly or indirectly controlled by a person who is subject to the mandatory disclosure requirement).