Current reports
Current report no. 24/2025
Disclosure of delayed inside information regarding the letter received by the Company from the Solkomtel Foundation and information from the Company's direct shareholder, i.e. Argumenol Investment Company Limited
Legal basis:
Art. 17 sec. 4 of MAR – notice of delayed disclosure of inside information
Content of the report:
Acting pursuant to art. 17 sec. 1 and 4 of the Regulation of the European Parliament and of the Council (EU) No. 596/2014 of April 16, 2014 („MAR”) ZE PAK SA seated in Konin („Company”) provides the following Inside Information regarding:
- the letter received by the Company from the Solkomtel Foundation („Solkomtel”, „Foundation”) containing information regarding the parent company of Solkomtel, Solkomtel's representatives and beneficiaries, and the ownership structure of related companies; and
- the information received from the Company’s direct shareholder, i.e. Argumenol Investment Company Limited.
The disclosure of the inside information was delayed on September 23rd, 2025 pursuant to art. 17 sec. 4 of MAR.
Content of the delayed inside information:
The Management Board of ZE PAK S.A. (the "Company") hereby announces that on September 23, 2025, the Company received a letter from the Solkomtel Foundation, based in Liechtenstein ("Solkomtel", "Foundation"), in connection with correspondence sent by the Company to Elektrim S.A. and by Elektrim S.A. to Stasalco Limited.
In the letter, the Solkomtel Foundation informs that, based on the definition contained in Article 4, Section 14 of the Act on Public Offering, the Foundation does not have a parent entity. In particular, there is no entity that:
- directly or indirectly holds the majority of votes in the Foundation’s governing body (Foundation Board), or
- has the authority to appoint or remove the majority of the Foundation Board membres, or
- more than half of the members of the mamagement board of such another entity are also members of the Foundation Board, proxies or persons performing managerial functions in the Foundation, or persons in managerial positions within the parent or its subsidiaries.
Simultaneously, The Solkomtel Foundation indicates in the letter that it does not have a management or supervisory board. Its governing body is the Foundation Board, which is responsible for managing the Foundation’s affairs and representation. The current members of the Foundation Board are:
- Peter Schierscher – appointed by the Princely Court in Vaduz, Liechtenstein;
- Jarosław Grzesiak – appointed jointly by Tobias Solorz, Aleksandra Żak and Piotr Żak;
- Tomasz Szeląg – appointed by Zygmunt Solorz.
The Foundation is represented jointly by Peter Schierscher acting together with either Tomasz Szeląg or Jarosław Grzesiak.
Furthermore, the Solkomtel Foundation informs in the letter that the register of beneficial owners of the Foundation sets out:
- Zygmunt Solorz as a founder, curator and first beneficiary (the sole economic beneficiary of the Foundation for life);
- Peter Schierscher as Foundation Board member;
- Jarosław Grzesiak as Foundation Board member;
- Tomasz Szeląg as Foundation Board member.
Moreover, in connection with the questions contained in the letters to the Foundation, the Foundation presented a detailed ownership structure of the companies that submitted questions in order to assess the connections within the capital group:
- The Foundation holds 100% of the shares in Stasalco Limited,
- Stasalco Limited holds 71.450.393 shares in Elektrim S.A. (85.29% of shares and votes at the general meeting of the company),
- Elektrim S.A. holds 100% of the shares in Anokymma Limited and Enelka Taahhüt Imalat ve Ticaret AS,
- Anokymma Limited and Enelka Taahhüt Imalat ve Ticaret AS together hold 100% certyficates in IB8 FIZAN,
- IB8 FIZAN holds 100% of the shares in Polynon Investments Limited, Progoria Investments Limited, Justiana Investments Limited, Iceneus Investments Limited,
- The companies indicated below hold shares in Argumenol Investment Company Limited in the following percentages: Elektrim S.A. – 11.5%, Anokymma Limited – 12.64%, IB8 FIZAN – 51.4%, Polynon Investments Limited – 3.67%, Progoria Investments Limited – 7.34%, Justiana Investments Limited – 4.89%, Iceneus Investments Limited – 8.56%.
The Company is publishing the content of the letter received from Solkomtel as an attachment to this current report.
Similarly, on September 23, 2025, the Company received information from its direct shareholder, Argumenol Investment Company Limited, based in Limassol, Cyprus ("Argumenol"), stating that Argumenol had received a letter from the Solkomtel Foundation with similar content as indicated above and that it had taken steps to analyze the aforementioned information. Argumenol also indicated that it would inform the Company of the results of the aforementioned analyses.
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Rationale for delayed disclosure of the Inside Information:
In the opinion of the Management Board of the Company, the delay in the disclosure of the above Inside Information, at the time the decision on delay was taken, met the conditions set out in MAR and in the guidelines of the European Securities and Markets Authority regarding the delay in disclosure of inside information of October 20, 2016.
The information contained in the letter received from the Solkomtel Foundation is precise, but its scope is significantly broader than the Company's existing knowledge and, therefore, its disclosures regarding its ownership structure. Furthermore, the Company received information from its direct shareholder, Argumenol, that Argumenol has commissioned additional analyses of the information received.
In the opinion of the Company's Management Board, under the circumstances described, immediate disclosure of the information contained in the letter from the Solkomtel Foundation creates a risk of infringement on the legitimate interests of the Company and its capital group through potentially incorrect interpretation of the information regarding the ownership structure of the Company's shares and, consequently, incorrect presentation in the Company's financial statements. The Company's Management Board has decided to delay the public disclosure of the Confidential Information until the Company receives the results of the analyses commissioned by Argumenol.
In the opinion of the Company's Management Board, there were no indications that the delay in disclosing the Confidential Information could mislead the public or investors, particularly given the lack of prior public announcements by the Company regarding the matter to which the Confidential Information relates. Therefore, there was no basis to conclude that the delay in disclosing the Confidential Information to the public was inconsistent with market expectations based on the Company's communications to date.
The Company's Management Board took the steps required by the MAR Regulation to maintain the confidentiality of the delayed Confidential Information until it is publicly disclosed, in particular through internal procedures for the circulation and protection of information implemented at the level of the Company's capital group. When the decision to delay the public disclosure of the Confidential Information was made, in accordance with Article 18 of the MAR Regulation, a list of individuals with access to the Confidential Information was prepared, which was monitored on an ongoing basis and updated as necessary. Individuals in possession of the confidential information were informed of the confidentiality of the information and of the Management Board's decision to delay the public disclosure.
Pursuant to art. 17 sec. 4, third paragraph of MAR, immediately after the delayed inside information is disclosed to the public, the Company will inform the Polish Financial Supervision Authority of the delay in disclosure of inside information along with an indication of the fulfilment of the conditions for such delay, in accordance with Art. 4 (3) of the Commission Implementing Regulation (EU) 2016/1055 of 29 June 2016 laying down implementing technical standards with regard to technical conditions for the proper disclosure of inside information to the public and delaying the disclosure of inside information to the public in accordance with the Regulation of the European Parliament and Council (EU) No. 596/2014.
Signatures of persons representing the Company:
Andrzej Janiszowski – President of the Management Board
Maciej Nietopiel – Vice President of the Management Board
Katarzyna Sobierajska – Vice President of the Management Board