02 Dec OPEN LETTER TO THE FINANCIAL SUPERVISION COMMISSION AND THE MANAGERS

from a new shareholder in ZAD ‘DallBogg: Life and Health’

Tihomir T. Kamenov,

law and economics student

at the University of St. Gallen and Harvard University

Ms Velichkova, Deputy Chair
You are involved in administrative arbitrariness, which, in my opinion, is coordinated by Chairman Golemanski, Deputy Chair Danailov and employees under their leadership. These actions create the impression among political institutions and society in Bulgaria that the campaign against the insurer is being carried out at the insistence or under the direction of EIOPA (the European Insurance and Occupational Pensions Authority). I know and have spoken personally with the Chair of EIOPA, Ms Petra Hilke, and I am convinced that she has neither given instructions nor has the authority to interfere in the activities of other national authorities such as the Commercial Register at the Ministry of Justice, the Bulgarian Stock Exchange or the Central Depository.

The actions you have taken effectively block the exercise of my shareholder rights. An extremely short deadline (1 day) has been set for objections against criminal proceedings against the insurer, without me, as a directly affected person, being duly addressed or summoned in the declaratory proceedings that you claim to be conducting against the Commercial Register. The facts giving rise to the right are present: a decision of the general meeting of shareholders, paid-in capital and entry in the Commercial Register. In this context, the FSC’s blocking of the reflection in the Central Depository, which is solely of a legal-technical nature, constitutes an inadmissible interference in my already my already established and duly registered shareholder rights.

I am convinced that the authoritative and independent Bulgarian court will rule competently on these issues and that, if necessary, European and international courts will protect the investor’s property rights.

As a national supervisory authority, the FSC should contribute to the financial stability and development of the insurance sector. The current campaign
to prevent the insurer’s further capitalisation and to cause it organised damage raises serious questions about the quality of the investment environment in the country.

I hope that the FSC will carefully reconsider its actions and stop this organised campaign, which seriously damages the public interest, the interests of
Bulgarian and foreign investors, and irreparably damages Bulgaria’s reputation.

Sent from Washington, D.C., USA