In 2025 Atlantic Grupa adopted a new Corporate Governance Code, which harmonizes corporate governance standards with European law, domestic regulations, and best international corporate governance practices.

The Code defines work procedures for the Supervisory Board, Management Board, and other entities responsible for corporate governance, mutual relationships, prevention of conflicts of interest, establishment of internal controls, and the creation of effective systems of accountability and information transparency.

Atlantic Grupa is a signatory of the Croatian Chamber of Commerce’s Code of ethics on business conduct, which outlines ethical behavior within the framework of the Croatian economy. This set of defined ethical criteria promotes transparent, efficient business operations, and cultivates healthier work environments and economic relationships in Croatia.

All code signatories are responsible for ethical conduct towards other companies, development of qualitative relations, and upholding standards of fair competition. The guidelines of the Code stipulate open public dialogue and active promotion of welfare for employees and the environment. In accordance with the moral and ethical guidelines laid out by the Croatian Chamber of Commerce, Atlantic Grupa conducts its business transparently, responsibly, and efficiently, to strengthen the quality of and trust in the Croatian economy as a whole.

The supplier code of conduct describes the principles and expectations that guide Atlantic Grupa's relationships with suppliers and ensure compliance with our commitment to ESG excellence in the supply chain. As part of our reporting obligations and as a prerequisite for compliance with internationally recognized standards, Atlantic Grupa shall be obliged to demonstrate how sustainability risk management, including those arising from relationships with suppliers, is integrated into its operations and how we ensure suppliers' compliance with our sustainability requirements. Compliance with the principles and requirements of the Code shall be considered a condition for maintaining a business relationship with our suppliers and the foundation for long-term and transparent cooperation.

To support its ambitious plans for growth, Atlantic’s dividend policy is based on the concept that the majority of revenue is retained by the company for purposes of reinvestment into its development initiatives.

Atlantic Grupa’s Dividend Policy will be implemented according to: development plans and the state of the capital market, the growth of net profits, revenue levels, expected property value growth, and other salient factors. When the aforementioned conditions are met, Atlantic intends to pay out up to 45% of consolidated profit as dividends to its shareholders.

In accordance with this policy, Atlantic’s Management and Supervisory Boards create proposals for dividend distribution, while the final decision regarding the amount and the manner of distribution is conducted by the General Assembly.

According to the Articles of Association of the Company, applicable regulations, and with prior consent of the Supervisory Board, the Management Board is authorized to pay out an advance on dividends to shareholders from the anticipated portion of net profits. Advance payments on dividends may amount to a maximum of half of the amount of yearly profit, minus the amount to be allocated to the company reserves pursuant to the law and the Articles of Association. Advance payments on dividends may not exceed 50% of last year’s profit.

Persons entitled to dividends are determined according to current, applicable laws and relevant practices of the Republic of Croatia.