REPORTING PERIOD
3 1 DECEMBER 2021
CONSOLIDATED FINANCIAL STATEMENTS

CONTENT
CONSOLIDATED STATEMENT OF FINANCIAL POSITION AS OF DECEMBER 31, 202 1 3
CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME AS OF DECEMBER 31, 202 1 5
CONSOLIDATED STATEMENT OF CHANGES IN EQUITY AS OF DECEMBER 31, 202 1 6
CONSOLIDATED STATEMENT OF CHANGES IN CASH FLOW AS OF DECEMBER 31, 202 1 7
EXPLANATORY NOTES TO THE ANNUAL INDIVIDUAL FINANCIAL STATEMENTS 8
ANNUAL REPORT ON BUSINESS ACTIVITIES 6 0
ADDITIONAL INFORMATION UNDER APPENDIX 11 TO ORDINANCE 2 8 9
DECLARATION FOR CORPORATE GOVERN ANCE 1 0 0
DECLARATION UNDER ARTICLE 100 117

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED STATEMENT OF FINANCIAL POSITION
AS OF DECEMBER 3 1 , 20 21
Unless otherwise stated, all amounts are in BGN thousand.
The consolidated statement of financial position should be read in conjunction with the explanatory notes set out on pages
from 8 to 59 , which form an integral part of the financial statements attached.
Page 3 of 117
ASSETS Notes December 3 1 ,
202 1
December 31,
20 20
Non - current assets
Property, plant and equipment 3.01 4 798 5 062
Intangible assets 3.02 3 116 3 643
Advances for acquisition of assets 19 -
Assets with right of use 3.03 108 46
Goodwill 3.04 160 2 801
Investments in associated companies 3.05 40 -
Other long - term capital investments 3.06 2 624 6566
Trade receivables 3.0 7 2 054 -
Deferred tax assets 3.0 8 72 485
Total non - current assets 12 991 18 603
Current assets
Inventory 3.0 9 7 560 3 660
Trade receivables 3. 10 19 167 13 948
Other receivables 3. 11 1 912 709
Cash and cash equivalents 3.1 2 30 541 26 050
Prepaid expenses 3.1 3 234 42
Total current assets 59 414 44 409
Non - current assets classified as held for sale
and assets included in disposal groups classified
as held for sale
3.14 - 2 681
TOTAL ASSETS 72405 65 693
Date : 29 April 20 2 2
Compiler of the financial statements: Executive Director:
/Albena Benkova Beneva/ / Dimitar Stoyanov Dimitrov /
Audit Company Marian Nikolov
Primorska Audit Company Ltd. Registered auditor, responsible for the audit
Reg. N: 086 Reg. N: 0601
Ilia Iliev
Managing Director

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED STATEMENT OF FINANCIAL POSITION ( continued)
AS OF DECEMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
The consolidated statement of financial position should be read in conjunction with the explanatory notes set out on pages
from 8 to 59 , which form an integral part of the financial statements attached.
Page 4 of 117
LIABILITIES Notes December 3 1 ,
2021
December 31,
2020
Non - current liabilities
Bank loans 3.1 5 2 007 2 518
Lease liabilities 3.1 6 80 31
Total non - current liabilities 2 087 2 549
Current liabilities
Current share of bank loans 3.1 5 572 511
Current share of lease liabilities 3.1 6 58 75
Trade payables 3.1 7 1487 1387
Payables to employees 3.1 8 173 194
Social security liabilities 115 96
Tax liabilities 3.1 9 1 315 395
Other liabilities 3. 20 1 026 1015
Total current liabilities 4 746 3 673
Liabilities related to non - current assets classified as held
for sale and assets included in disposal groups classified
as held for sale
- 2 635
TOTAL LIABILITIES 6 833 8 857
EQUITY
Registered capital 3. 2 1 18 000 18 000
Retained earnings 3. 2 2 39 394 26 938
Reserves 3.2 3 1 800 1 500
Reserve from issue of shares 3.2 4 5 403 5 703
Treasury shares - (138)
Other comprehensive income 3.2 5 1 036 4 849
Foreign exchange rate differences from translation of
financial statements of foreign operations (61) 280
Equity attributable to the holders of the parent -
company's equity 65 572 57 132
Minority interest - (296)
TOTAL EQUITY 65 572 56 836
TOTAL LIABILITIES AND EQUITY 72405 65 693
Date: 29 April 202 2
Compiler of the financial statements: Executive Director:
/Albena Benkova Beneva/ / Dimitar Stoyanov Dimitrov /
Audit Company Marian Nikolov
Primorska Audit Company Ltd. Registered auditor, responsible for the audit
Reg. N: 086 Reg. N: 0601
Ilia Iliev
Managing Director

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED STATEMENT OF COMPREHENSIVE INCOME
FOR THE PERIOD JANUARY 1, 20 2 1 – DECEMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
The consolidated statement of comprehensive income should be read in conjunction with the explanatory notes set
out on pages from 8 to 59 , which form an integral part of the financial statemen ts attached.
Page 5 of 117
Notes 202 1 20 20
(reclassified)
Revenue from sale 4.01 59 509 46 342
Cost price of sales 4.01 (26 722) (24 648)
Gross profit 32 787 21 694
Other operating income 4.02 1 498 1 013
Sales and marketing expenses (2 696) (542)
Administrative expenses 4.0 3 (12 170) (8699 )
Other operating expenses 4.0 4 (713) ( 1 115 )
Profit from operating activities 18 706 12 351
Financial income 4.0 5 250 3 446
Financial expenses 4.0 6 (266) (849)
Share in the profit of associated companies 2.11.7 32 -
Profit from the ordinary activities 18722 14 948
Profit before tax on profit 18722 14 948
Corporate profit tax income (expense) 4.07 (2 760) (1 510)
Profit for the period from continuing operations 15 962 14 722
Profit/(loss) for the period from discontinued operations - (1 284)
Net profit 15 962 13 438
Other comprehensive income:
Items that can be reclassified to the profit or loss
From other long - term capital instruments (3 573) 4 849
Foreign exchange rate differences from translation of
statements of foreign operations (95) 98
Foreign exchange rate differences of sold investments (246) -
Other comprehensive income for the period, after
taxation (3 914) 4 947
TOTAL COMPREHENSIVE INCOME 12 048 18 385
Net profit attributable to:
Owners of the Parent - company 15 962 13 857
Minority interests - (419)
Other comprehensive income attributable to:
Owners of the Parent - company (3 914) 4 958
Minority interests - (11)
Total comprehensive income attributable to:
Owners of the Parent - company 12 048 18 815
Minority interests - (430)
Net income per share 0.887 0.875
Date: 29 April 202 2
Compiler of the financial statements: Executive Director:
/Albena Benkova Beneva/ / Dimitar Stoyanov Dimitrov /
Audit Company Marian Nikolov
Primorska Audit Company Ltd. Registered auditor, responsible for the audit
Reg. N: 086 Reg. N: 060 1
Ilia Iliev
Managing Director

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED FINANCIAL STATEMENT OF CHANGES IN EQUITY FOR THE PERIOD
ENDING ON DECEMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
The consolidated statement of changes in equity should be read in conjunction with the explanatory notes set out on
pages from 8 to 59 , which form an integral part of the financial statements attached.
Page 6 of 117
Registere
d capital
Retained
earnings
Share
premiu
m
reserves Reserve
s
Treasur
y shares
Foreign
exchange
rate
differences
from
translation
of fin . Stat .
of foreign
operations
Total Minority
interest
Total
equity
Balance as of January 1, 2020 15 000 13 531 - 1 500 - 182 30 213 123 30 336
Capital increase 3 000 - 6 000 - - - 9 000 - 9 000
Expenses related to the increase of
the capital - - (297) - - - (297) - (297)
Total comprehensive income ,
including: - 18 706 - - - 109 18 815 (430) 18 385
Net Profit - 13 857 - - - - 13 857 (419) 13 438
Other comprehensive income - 4 849 - - - 109 4 958 (11) 4 947
Foreign exchange rate differences
from translation of fin. Stat. of sold
foreign operations
- - - - - (11) (11) - (11)
Distribution of dividends - (450) - - - - (450) - (450)
Change in minority interest - - - - - - - 11 11
Treasury shares - - - - (138) - (138) - (138)
Balance as of December 31, 2020 18 000 31 787 5 703 1 500 (138) 280 57 132 (296) 56 836
Balance as of January 1, 2021 18 000 31787 5 703 1 500 (138) 280 57 132 (296) 56 836
Transfer to reserves - - (300) 300 - - - - -
Total comprehensive income ,
including: - 12 389 - - - (341) 12 048 - 12 048
Net Profit - 15 962 - - - - 15 962 - 15 962
Other comprehensive income - (3 573) - - - (341) (3 914) - (3 914)
Other movements - (240) - - - - (240) - (240)
Dividend distribution - (3 600) - - - - (3 600) - (3 600)
Sale of treasury shares - - - - 138 138 - 138
Change in minority interest - (296) - - - - (296) 296 -
Effect from sale of subsidiaries - 390 - - - - 390 - 390
Balance as of December 31 , 2021 18 000 40430 5 403 1 800 - (61) 65 572 - 65 572
Date: 29 April 202 2
Compiler of the financial statements: Executive Director:
/Albena Benkova Beneva/ / Dimitar Stoyanov Dimitrov/
Audit Company Marian Nikolov
Primorska Audit Company Ltd. Registered auditor, responsible for the audit
Reg. N: 086 Reg. N: 0601
Ilia Iliev
Managing Director

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED FINANCIAL STATEMENT OF CASH FLOW
FOR THE PERIOD JANUARY 1, 20 2 1 – DECEMBER 3 1 , 202 1
Unless otherwise stated, all amounts are in BGN thousand.
The consolidated statement of cash flow should be read in conjunction with the explanatory notes set out on pages
from 8 to 59 , which form an integral part of the financial statements attached.
Page 7 of 117
Notes 202 1 20 20
Cash flows from operating activity
Proceeds from clients 57 364 47 320
Payments to suppliers (36 973) (31 199)
Payments related to financial assets held for trade - (138)
Payments for taxes ( 3218) (2 854)
Paid corporate tax (2 087) (2 468)
Payments to employees and social security (6 972) (6 238)
Cash flow from positive (negative) exchange rate differences 150 (94 )
Other proceeds/payments, net ( 139) (272)
Net cash flows from operating activities 8 125 4 057
Cash flow from investment activities
Cash flows related to non - current tangible and intangible assets (1 583) (2 869)
Cash from sale of fixed assets 44 10
Sale of investments 2 054 4 786
Purchase of investments ( 18 ) -
Net cash flows from investment activities 497 1 927
Cash flow from financing activities
Proceeds from capital increase - 9 000
Financial leasing payments ( 75 ) ( 124)
Loans received - 880
Loans paid (502) ( 775)
Cash flows related to interest and commissions (73) (80)
Dividend paid (3 436) (248)
Other income / payments, net (45) 552
Net cash flow from financing activities (4 131) 9 205
Net increase in available cash and cash equivalents for the period 4 491 15 189
Available cash and cash equivalents in the beginning of the period 26 050 10 931
Available cash and cash equivalents at the end of the period 3.1 2 30 541 26 120
Available cash, assets held for sale - (70)
Available cash and equivalents at the end of the period 30 541 26 050
Date: 29 April 202 2
Compiler of the financial statements: Executive Director:
/Albena Benkova Beneva/ / Dimitar Stoyanov Dimitrov/
Audit Company Marian Nikolov
Primorska Audit Company Ltd. Registered auditor, responsible for the audit
Reg. N: 086 Reg. N: 0601
Ilia Iliev
Managing Director

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 8 of 117
1. Information about the Group ................................ ................................ ................................ ..................... 11
1.1. Legal status ................................ ................................ ................................ ................................ ............... 11
1.2. Ownership and Management ................................ ................................ ................................ .................... 11
1.3. Scope of Activities ................................ ................................ ................................ ................................ .... 12
1.4. Group structure ................................ ................................ ................................ ................................ ......... 12
2. Basics of preparation of financial statements and accounting policies ................................ ..................... 13
2.1. General framework of financial reporting ................................ ................................ ................................ . 13
2.2. Initial application of new and amended IFRSs in force for the current accounting period ....................... 13
2.3. Accounting principles ................................ ................................ ................................ ............................... 16
2.4. Comparative data ................................ ................................ ................................ ................................ ...... 16
2.5. Functional currency and recognition of currency exchange rate differences ................................ ............ 16
2.6. Transactions and balances ................................ ................................ ................................ ......................... 17
2.7. Assumptions ................................ ................................ ................................ ................................ .............. 18
2.8. Subsidiaries and associated companies ................................ ................................ ................................ ..... 18
2.9. Minority interest ................................ ................................ ................................ ................................ ....... 18
2.10. Consolidation ................................ ................................ ................................ ................................ ............ 18
2.11. Definition and assessment of the items in the consolidated financial statements ................................ ..... 19
2.11.1. Revenues ................................ ................................ ................................ ................................ ................... 19
2.11.2. Expenses ................................ ................................ ................................ ................................ ................... 21
2.11.3. Property, plant and equipment ................................ ................................ ................................ .................. 21
2.11.4. Intangible assets ................................ ................................ ................................ ................................ ........ 23
2.11.5. Goodwill ................................ ................................ ................................ ................................ ................... 23
2.11.6. Other long - term capital investments ................................ ................................ ................................ ......... 24
2.11.7. Investments in Associated companies ................................ ................................ ................................ ....... 24
2.11.8. Non - current assets held for sale ................................ ................................ ................................ ................ 25
2.11.9. Inventories ................................ ................................ ................................ ................................ ................ 25
2.11.10. Financial instruments ................................ ................................ ................................ ................................ 25
2.11.11. Cash and cash equivalent ................................ ................................ ................................ .......................... 28
2.11.12. Leasing ................................ ................................ ................................ ................................ ...................... 29
2.11.13. Provisions ................................ ................................ ................................ ................................ ................. 30
2.11.14. Liabilities to employees ................................ ................................ ................................ ............................ 30
2.11.15. Share capital ................................ ................................ ................................ ................................ .............. 31
2.11.16. Income tax expenses ................................ ................................ ................................ ................................ . 32
2.11.17. Earnings per share ................................ ................................ ................................ ................................ ..... 33
2.11.18. Judgments that are crucial in applying accounting policies of the Group. ................................ ................ 33

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 9 of 117
2.11.19. Fair values ................................ ................................ ................................ ................................ ................. 34
3. Notes to the consolidated statement of financial position ................................ ................................ ....................... 35
3.01. Property, plant and equipment ................................ ................................ ................................ .................. 35
3.02. Intangible assets ................................ ................................ ................................ ................................ ........ 36
3.03. Assets with right of use ................................ ................................ ................................ ............................. 37
3.04. Goodwill ................................ ................................ ................................ ................................ ................... 37
3.05. Investme nts in associated companies ................................ ................................ ................................ ........ 38
3.06. Other long - term capital investments ................................ ................................ ................................ ......... 38
3.07. Long - term trade receivables ................................ ................................ ................................ ...................... 38
3.08. Deferred tax assets ................................ ................................ ................................ ................................ .... 39
3.09. Inventories ................................ ................................ ................................ ................................ ................ 39
3.10. Trade receivables ................................ ................................ ................................ ................................ ...... 40
3.11. Other receivables ................................ ................................ ................................ ................................ ...... 40
3.12. Cash and cash equivalents ................................ ................................ ................................ ........................ 41
3.13. Prepaid expenses ................................ ................................ ................................ ................................ ....... 41
3.14. Non - current assets classified as held for sale and assets included in disposal groups classified as held for
sale 41
3.15. Bank loans ................................ ................................ ................................ ................................ ................ 42
3.16. Lease ................................ ................................ ................................ ................................ ......................... 43
3.17. Trade payables ................................ ................................ ................................ ................................ .......... 43
3.18. Payables to employees ................................ ................................ ................................ .............................. 43
3.19. Tax liabilities ................................ ................................ ................................ ................................ ............ 44
3.20. Other liabilities ................................ ................................ ................................ ................................ ......... 44
3.21. Registered capital ................................ ................................ ................................ ................................ ...... 44
3.22. Retained earnings ................................ ................................ ................................ ................................ ...... 45
3.23. Reserves ................................ ................................ ................................ ................................ .................... 45
3.24. Reserve from issue of shares ................................ ................................ ................................ ..................... 45
3.25. Other comprehensive income ................................ ................................ ................................ .................... 46
4. Notes to the consolidated statement of comprehensive income ................................ ................................ 46
4.01. Sales revenue and cost price of sales ................................ ................................ ................................ ........ 46
4.02. Other operating income ................................ ................................ ................................ ............................. 46
4.03. Administrative expenses ................................ ................................ ................................ ........................... 47
4.04. Other operating expenses ................................ ................................ ................................ .......................... 47
4.05. Financial income ................................ ................................ ................................ ................................ ....... 48
4.06. Financial expenses ................................ ................................ ................................ ................................ .... 48
4.07. Tax expenses ................................ ................................ ................................ ................................ ............. 48
5. Contingent liabilities and commitments ................................ ................................ ................................ .... 49
6. Transactions with related parties ................................ ................................ ................................ ............... 49
7. Financial instruments by category ................................ ................................ ................................ ............ 50

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 10 of 117
8. Financial risk management ................................ ................................ ................................ ....................... 51
9. Fair value ................................ ................................ ................................ ................................ .................. 56
10. Events after the end of reporting period ................................ ................................ ................................ .... 57

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 11 of 117
1. Information about the Group
1.1. Legal status
Allterco JSCo (the mother company) , Sofia, is entered in the Commercial Register of the Registry Agency
with UIC as per Bulstat (Unified Identification Code as per the Bulgarian Statistical Register): 201047670 and
LEI code 8945007IDGKD0KZ4HD95 . The company is with reg istered office and address of management in
Bulgaria, Sofia 1407, 103, Cherni V rah Blvd. No changes in the seat, address or the name of the company
were made during the reporting period. The initial registered capital was BGN 5,488,000 (five million four
hundred and eighty - eight thousand), distributed in 5,488,000 ordinary registered voting shares with nominal
value of BGN 1.00 each. At the end of 2015, the capital was increased to BGN 13,500 thousand through cash
and non - cash contributions. At the end of 2016, the capital was increased to BGN 15,000 thousand after the
successful I nitial P ublic O ffering on the Bulgarian Stock Exchange. In 2020, the capital was increased to BGN
18,000 thousand as a result of a procedure for Secondary Public Offering of a new issue of shares. The public
offering of shares was carried out in the period September 28, 2020 – October 30, 2020 on the basis of a
Prospectus, together with the supplements to it, confirmed by the Financial Supervision Commission with
Decision No 148 - F of February 18, 2020, Decision No 405 - E of June 11, 2020, Decision No 601 - E of August
13, 2020 and Decision No 791 - E of October 29, 2020.
Since November 22, 2021 the shares of Allterco are trade d on the Frankfurt Stock Exchang e.
As of December 31, 2022 t he Group is managed and represented by Svetlin Todorov and Dimitar Dimitrov
jointly and separately .
Current financial statements are approved by the Board of Directors on 29 April, 2022
1.2. Ownership and Management
The Allterco Group includes Allterco JSCo . (the parent - company) and its subsidiaries, in which the parent -
company has a direct or indirect controlling interest. Allterco JSCo . is a public company in Bulgaria under the
Public Offering of Securities Act.
The dis tribution of the share capital of the company Allterco JSCo . as of 31 December 2021, is as follows:
Name Number of
shares : % in the capital
Svetlin Todorov 5 847 120 32.48%
Dimitar Dimitrov 5 847 120 32.48%
Persons holding les s than 5% of the capital
Other physical persons and legal entities 6 305 759 35 . 04 %
Total 17 999 999 100.00%
Allterco JSCo. is managed and represented by Svetlin Todorov and Dimitar Dimitrov .
As of December 31, 2021 m embers of the Board of Directors are :

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 12 of 117
• Dimitar Stoyanov Dimitrov
• Nikolay Angelov Martinov
• Svetlin Iliev Todorov
1.3. Scope of Activities
The scope of activities of Allterco JSCo includes the acquisition, management, evaluation and sale of
participations in Bulgarian and foreign companies; acquisition, management and sale of bonds; acquisition,
evaluation and sale of patents, assignment of licenses for use of patents to companies in which the Company
participates; financing of companies in which the Company participates.
The scope of activities of group companies include s development, p roduction and trade with IoT (Internet of
Things) devices and management of real estate owned by the Grou p.
1.4. Group structure
As of December 3 1 , 20 2 1 the Group included Allterco JSCo . and the following subsidiaries :
Name of the compan y
December 31 202 1 December 31
20 20
Percentage of
participation
Percentage of
participation
In the country
ALLTERCO TRADING OOD (Ltd.) 100% 100%
ALLTERCO ROBOTICS EOOD (Solely - owned LLC) 100% 100%
ALLTERCO PROPERTIES EOOD (Solely - owned LLC) 100% 100%
Name of the company
December 31 2021 December 31
2020
Percentage of
participation
Percentage of
participation
Abroad
ALLTERCO PTE LTD., Singapore - 100%
ALLTERCO SDN LTD., Malaysia - 100%
ALLTERCO CO. LTD, Thailand - 49%
ALLTERCO ROBOTICS INC, USA 100% 100%
ALLTERCO EUROPE GMBH, GERMANY 100% -
In the beginning of 2021 Allterco JSCo . acquired a stake in newly established (associated) company in China
– Allterco Asia Ltd., with a seat and office in Shenzhen. The registered share capital of the newly registered
company is CNY 100 000 . A llterco acquired 30 % stake and holds an option to acquire additional up to 50%
extend ing its total shareholding up to 80%.
In September 2021 Allterco sold its participation in the capital of 3 Asian subsidiaries. See Note 3.14 for
more details about the de al.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 13 of 117
In December 2021 Alltreco JSCo. established a new subsidiary in Germany. The name of the new subsidiary
is Allterco Europe GmbH and its registered capital is EUR 500 000 and it is 100% owned by Allterco.
2. Basics of preparation of financial statements a nd accounting policies
2.1. General framework of financial reporting
The Group maintains its current accounting and prepares its financial statements in accordance with the
requirements of the Bulgarian commercial and accounting legislation.
These financial statements have been prepared in accordance with the requirements of the Int ernational
Accounting Standards, published by the International Accounting Standards Board and adopted by the
European Union. As of December 31, 2021, IASs include the International Accounting Standards (IASs), the
International Financial Reporting Standar ds (IFRSs), the Interpretations of the Standing Interpretation
Committee and the Interpretations of the IFRS Interpretation Committee, approved by the IAS Committee and
in power since January 1 20201.
The IAS Committee issues every year the standards and their interpretations, which after the formal approval
by the EC, are valid for the year in which they are issued. However, a big part of them is not applicable to the
company's business because of the specific issues that are addressed in them.
2.2. Initial a pplication of new and amended IFRSs in force for the current accounting period
2.2.1. Accounting standards applicable for the current reporting period
The below mentioned amendments in the standards are adopted by the Commission of EU and are valid durin g
2021:
Standard or Interpretation, date of
amendment and date of implementation
Name of the Standard or
Interpretation
Effect on individual financial
statements of the Company
Amendments to IFRS 9, IAS 39,
IFRS 7, IFRS 4 and IFRS 16, issued on 27
August 2020, valid for the periods starting at
and after 1 January 2021
Interest Rate Benchmark Reform –
Phase 2
No impact on the individual
financial statements of the
Company
Amendments to IFRS 4, issued on 25 June
2020, valid for periods starting at or after 1
January 2021
Insurance contracts –
postponement of implementation
of IFRS 9
No impact on the individual
financial statements of the
Company
Amendments to IFRS 16, issued on 31 March
2021, valid for periods starting at or after 1
April 2021
COVID 19 – discounts related to
rents after 30 June 2021
No impact on the individual
financial statements of the
Company
Impact from the initial implementation of the Interest Rate Benchmark Reform – Phase 2
Amendments to IFRS 9, IAS 39, IFRS 7, IFRS 4 and IFRS 16 Interest Rate Benchmark Reform – Phase 2
During the previous year the Amendments to IFRS 9/ IAS 39 and IFRS 7 Interest Rate Ben chmark Reform –
Phase 1 change some specific requirements to accounting treatments of hedging in order to allow the

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 14 of 117
accounting treatment of affected hedges to continue in a period of uncertainty, before the hedged positions or
instruments be changes as a r esult of the ongoing Interest Rate Benchmark Reform
During the current year the Amendments to IFRS 9, IAS 39, IFRS 7, IFRS 4 and IFRS 16 Interest Rate
Benchmark Reform – Phase 2, allow the companies to recognize the effect from switching from the existing
base interest rates (IBOR) to alternative base interest rates (called also “risk free” rates or RFR), without
making accounting changes, which would not provide useful information to the readers of financial statements.
The goals of the amendments from Phase 2 are to help the companies in:
а) the application of IFRS standards when changes are made in the agreed cash flows and hedging
relationships due to the reform of the base interest rate; and
б) providing useful information to the readers of fin ancial statements.
The Phase 2 amendments to the requirements of IFRS 9, IAS 39, IFRS 7, IFRS 4 and IFRS 16 refer to:
а) changes in the principles for determining the contractually agreed cashflows from financial assets,
financial liabilities and lease lia bilities;
б) reporting of hedging; and
в) related notes.
The amendment made with Phase 2 apply only to changes required by the reform of benchmark interest for
financial instruments and hedging relationships.
The amendments made with Phase 1 and Phase 2 do not have an effect on the Company as it does not use
hedging on the positions owned, which are subject to risk of change in the benchmark interest rate .
Amendment to IFRS 4 Insurance Contracts – postponement of the application of IFRS 9
In June 2020 IA SC issued Amendments to IFRS 17 as a response to the importance and challenges for the
application, which were identified after the release of IFRS 17. The amendments postpone the initial
application of IFRS 17 (including amendments) for the annual financi al periods starting at or after 1 January
2023.
At the same time IASC issues Prolongation of temporary relief from the application of IFRS 9 (Amendment to
IFRS 4) , which prolonged the set date for the end of the temporary relief from application of IFRS 9 in IFRS
4 to the annual reporting period starting at or after 1 January 2023.
The amendments do not have an effect on the Company as it is not in the insurance business.
Amendments to IFRS 16 COVID 19 – discounts related to rents , applicable after 30 June 2021
In May 2020 IASC issued Amendments to IFRS 16 - COVID 19 – discounts related to rents. Those amendments
provide relief to tenants for the reporting of discounts related to rent payments, which are a consequence of

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 15 of 117
COVID 19 , introducing practical measures in IFRS 16. As practical measure the tenant may choose not to
asses if a rent discount related to COVID 19 is change in the rent contract. The tenants that make this choice
reports all payments related to the rent after the rent discount , in the same way this change would have been
in the application of IFRS 16, should no change in the rent contract was made.
The practical measures apply only to the rent discounts resulting from COVID 19 pandemic and only if the
below listed conditions ar e met:
a) The change in rent payments leads to change in the rent contract as the amended remuneration does
not exceed the rent remuneration immediately before the change;
b) Any discount of rent payments concerns only the payments which were initially due on or before 30
June 2021 (for example a rent discount meets this requirement if it generates lower rent payments on
or before 30 June 2021 as well as higher rent payments after 30 June 2021); and
c) The remaining terms of the rent contract do not change substanti ally.
In March 2021 IASC issued Amendments to IFRS 16 - COVID 19 – discounts related to rents after 30 June
2021 , which allow the rent reliefs to be applied to rent payments initially due on or before 30 June 2022.
The amendments do not affect the Group as it does not use and rent discounts related to rent payments as a
result of COVID 19 .
2.2.2. Standards and interpretations issues by International Accounting Standards Committee (IASC)
and adopted by the EU Commission, which are still not applicable
Standard or interpretation, date of
amendment and enforcement
Name of the standard or interpretation Date of adoption by EU
Commission
Amendments to IFRS 3, IAS 16 и IAS 37,
issued on 14 May 2020, applicable to
annual financial periods starting at or after
1 January 2022
Annual improvements 2018 - 2020 28 June 2021
IFRS 17 issued on 18 May 2017, including
amendments to IFRS 17 issued on 25 June
2020, applicable to annual financial
periods starting at or after 1 January 2023
Insurance contracts 19 November 2021
The Group did not apply the above - mentioned standards, which are adopted by the EU but still are not in force.
The management of the Group expects that t he application of the above - mentioned contracts will not have
significant effect on the individual financial statements of the Group for future periods.
2.2.3. Standards and clarifications issued by IASC awaiting adoption by the EU Commission
Standard or clarification, date of
amendment and enforcement
Name of the standard or clarification Adoption status by EU
Commission
Amendments to IAS 1 issued on
23 January 2020 and 15 July 2020, in effect
Classification of liabilities as current or
non - current and classification of assets
Waiting for a date of
adoption

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 16 of 117
for annual financial periods starting at or
after 1 January 2023
as current and non - current –
postponement of enforcement date
A mendments to IAS 1 issued on
12 February 2021, in effect for annual
financial periods starting at or after
1 January 2023
Financial statements presentation and
disclosure of accounting policies
Waiting for a date for
adoption
Amendments to IAS 8 issued on
12 February 2021, in effect for annual
financial periods starting at or after
1 January 2023
Accounting policies, Amendments in
the accounting assessments and
mistakes: Definition of accounting
assessments
Waiting for a date for
adoption
Amendments to IAS 12, issued on 7 May
2021, in effect for annual financial periods
starting at on after 1 January 2023
Corporate profit tax: Deferred tax
related to assets and liabilities arising
from one deal
Waiting for a date for
adoption
IFRS 17 issued on 9 December 2021, in
effect for annual financial periods starting
at or after 1 January 2023
Insurance contracts: Initial application
of IFRS 17 and IFRS 9 – Comparable
data
Submitted for adoption by
the Commission, expected
to be adopted during t he
first quarter of 2022
2.3. Accounting principles
The consolidated financial statements of the Group have been prepared in accordance with the going concern
principle. The latter assumes that the Group will continue to exist in the foreseeable future.
Durin g the last reporting period the COVID - 19 pandemic did not cause any negative effect on the business
activities of the Group .
The Management has no plans or intentions to sell the business or discontinue the operations, which could
significantly change the book value or classification of the assets and liabilities recognized in the financial
statements.
The valuation of assets and liabilities and the measurement of income and expenses are carried out in
compliance with the principle of historical cost. This principle has been modified in certain cases by revaluing
certain assets and / or liabilities to their fair value at December 31 of the current or previous year, as set out
below.
2.4. Comparative data
The Bulgarian legislation stipulates that the financial year ends on December 31 and the companies must
present their financial statements at this date together with comparative data for the previous year. When
necessary, the comparative data for the previous year is reclassified in order to obtain comparability between
the data in the current and previous periods.
2.5. Functional currency and recognition of currency exchange rate differences
Functional and Reporting Currency
The accounting currency for the presentatio n of the elements of the consolidated financial statements is the
Bulgarian Lev (BGN), which is the functional currency of Allterco JSCo.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 17 of 117
The data in the elements of the consolidated financial statements and the notes thereto are presented in
thousands of BGN, unless explicitly stated otherwise. When presented in the financial statements and the
explanatory notes, amounts over BGN 500 are rounded to BGN 1 thousand.
The Group's companies keep their accounting records in the functional currency of the country in which they
operate. The effects of exchange rate differences related to the settlement of foreign currency transactions or
the accounting of foreign exchange transactions at rates other than those at which they were initially recognized
are included in the statement of comprehensive income at the time they occur, are treated as “other operating
income and loss”, except for those related to investments and loans denominated in foreign currency, which
are presented as “investment income” and “financial ex penses”. Non - monetary assets and liabilities initially
denominated in foreign currencies should be translated to the functional currency using the historical exchange
rate at the date of the transaction and subsequently not revaluated at the closing exchan ge rate.
2.6. Transactions and balances
A transaction in foreign currency is recognized initially in the functional currency by applying the foreign
currency exchange rate (spot) between the functional currency and the foreign currency at the time of the
trans action or operation.
At each date of financial statement preparation:
(a) monetary positions, receivables and payables denominated in foreign currency are recalculated into
the functional currency using the exchange rate published by the BNB on the last b usiness day of the month
of the report;
(b) non - monetary items held at historical cost in a foreign currency are translated using the exchange
rate at the date of the transaction, if an exchange rate other than that of the transaction (average monthly, dai ly
or other) is applied; and
(c) non - monetary items held at fair value in a foreign currency are recalculated using the exchange rates
at the date when the fair value was determined.
Foreign currency exchange differences are recognized in accordance with IAS 21 the Effects of Changes in
Foreign Exchange Rates.
The items of the consolidated statement of financial position and consolidated statement of comprehensive
income of foreign companies of the Group, using a functional currency other t han Bulgarian lev, are translated
into BGN to be included in the consolidated statement of the group as follows
▪ All monetary and non - monetary assets and liabilities (including comparative information) are
recalculated at the BNB closing exchange rate at th e date of the relevant statement of financial
position;
▪ The income and expense items of each comprehensive income statement are recalculated at the

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 18 of 117
accounting date at the weighted average exchange rate for the accounting year;
▪ All exchange rate differences obtained are recognized as other comprehensive income.
▪ The cumulative amount of these exchange rate differences is presented in a separate component of
equity until the foreign operation is released.
2.7. Assumptions
The presentation of financial statements in accordance with International Financial Reporting Standards
requires the management to make the best estimates, accruals and reasonable assumptions that have an effect
on the reported values of assets and liabili ties, of income and expenses, and of the disclosure of contingent
receivables and liabilities. These estimates, accruals and assumptions are based on the best assessment us i ng
the available information at the date of preparation of the financial statements , and therefore future actual
results may differ from the amounts presented in the current financial statements .
2.8. Subsidiaries and associated companies
Subsidiaries are the entities over which Allterco JSCo . exercises control as defined in IFRS 10 Consolid ated
Financial Statements.
The parent - company (the investor) controls the investee company if it has:
▪ Rights over the ownership of the subsidiary ;
▪ Rights over the variable returns from its participation in the subsidiary ;
▪ Ability to use its powers over the entity in order to influence the size of return on investment.
Subsidiaries are considered controlled starting from the date on which control is acquired by the Group and
they cease to be consolidate d on the date when the control have been lost.
Associated company is a company in which the Group has significant influence on decisions regarding
operating and financial policies, but without being able to fully control those policies.
2.9. Minority interest
Minority interest is valued at the proportion ate share of identifiable net assets at the acquisition date.
2.10. Consolidation
The consolidated financial statements of the G roup include the financial statements of the parent company and
the subsidiaries. All assets, liabilities, capital, income, expenses and cash flows of the group companies are
presented as such as they belong to just one entity .
Subsidiaries are those entities that are controlled by the parent company. Control occurs when the parent
company exercises its rights on variable return arisi ng from its participation in the subsidiary’s capital and has

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 19 of 117
the ability to influence this return from investment through its power. The consolidated financial statements
have been prepared following the same accounting policies with respect to similar tr ansactions and business
facts of all companies in the group. All mutual interests, as well as significant internal transactions, balances
and unrealized gains in the Group are eliminated and the financial statements are prepared using the full
consolidatio n method. The financial results of operations of the subsidiaries are included in the consolidated
financial statements from the date of acquisition of control over them and cease to be consolidated from the
date on which such control is lost. When a subsi diary is acquired as a result of an internal group restructuring,
its net assets and financial result are included from the beginning of the earliest accounting period presented
in the financial statements.
2.11. Definition and assessment of the items in the con solidated financial statements
2.11.1. Revenues
Revenue from sales and operating expenses has been accrued at the time of their occurrence, regardless of cash
receipts and payments. The accounting and recognition of revenue and expenses should be carried out in
compliance with the requirement for a caus e - consequence connection between them.
Revenue is measured at the fair value of the remuneration received or to be received or paid, less any discounts
provided.
The Group recognizes revenue when the amount of revenue can be measured reliably, when it is possible for
the Group to obtain future economic benefits, and when it meets specific criteria for each of the Group's
activities, as specified below.
Amounts collected on behalf of third parties, such as sales taxes and value added tax, are excluded fro m
revenue.
▪ Revenue recognition under contracts with customers
Revenues in the Group are recognized when the control over the goods and/or services promised in the contract
with the customer are transferred to the customer. The control is transferred to the customer upon fulfilment
of the contractual obligations by tr ansferring the promised goods and/or rendering the promised services as in
general the Group generally controls the goods or services before transferring them to the customer.
The Group recognizes revenue when it meets its obligations under the terms of th e contract, by transferring
the promised service to the customer. An asset (good or service) is recognized as transferred after the customer
obtains control over that asset.
▪ Evaluation of a contract with a c ustomer
There is a contract with a c ustomer o nly when upon its entry into force it:
✓ it has a commercial nature and motive;

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 20 of 117
✓ the parties have approved it (orally, in writing or on the basis of "established and generally
accepted business practice") and have undertaken to fulfil it;
✓ the rights of each party can be identified in relation to the goods or services to be transferred;
✓ payment terms can be identified; and
✓ there is a probability that the remuneration to which the company is entitled in the performance
of its obligations will be receive d.
A contract for which one of the above criteria has not yet been met is subject to a new evaluation in each
reporting period. Remuneration received under such a contract is recognized as a liability (liability under the
contract) in the Statement of fina ncial position until:
✓ all criteria for recognition of a contract with a c ustomer are met;
✓ the company has fulfilled its obligations and has received all or almost all of the remuneration
(which is not refundable); and / or
✓ when the contract is terminated a nd the remuneration received is not refundable.
In the initial evaluation of its contracts with customers, the Company makes an additional analysis and
assessment of whether two or more contracts should be considered in their combination and should be rep orted
as one and resp ectively whether the promised goods and / or services in each individual and / or combined
contract must be accounted for as one and / or more performance obligations.
Any promise to transfer goods and / or services that are distingui shable (themselves and in the context of the
contract) is accounted for as a single performance obligation.
The Company recognizes revenue for each individual obligation to perform within an individual contract
with a c ustomer by analyzing the type, term and conditions for each specific contract.
▪ Measurement of revenues under contracts with c ustomers
The revenue is measured on the basis of the transaction price determined for each contract.
The transaction price is the amount of the remuneration to which the Company expects to be entitled, except
for the amounts collected on behalf of third parties. In determining the transaction price, the Company takes
into account the terms of the contract and its usual commer cial practices.
▪ Transaction price and payment terms
The transaction price usually includes a fixed sale price, according to a general or c ustomer price list.
▪ Variable remuneration
The Variable remuneration is included in the transaction price only to the e xtent that it is highly probable that
no significant adjustment will be made to the amount of revenue recognized cumulatively.
Revenue from services
The company reports revenues from services, complying with the commitments under the contract. Revenues

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 21 of 117
fro m services are reported upon final completion of the services (by sites) recognized as performed.
Other income / revenues
Other income and revenues are recognized when the right to receive them is established.
The Group companies apply IFRS 15 and the man agement carefully examine s its trad e practices for possible
changes at the time of revenue recognition. No change in the obligations for performance and the distribution
of the price of the contracts and recognition of revenues is needed for the reporting period .
Depending on the nature of the activity and the contracts with the clients, the management has assessed the
categories of revenue breakdown and has disclosed them in Note 4.01 .
2.11.2. Expenses
The expenses of the Group are recognized at the time of their occurrence and o n the basis of the accrual and
comparability principles. Expenses are recognized when there is a decrease in future economic benefits
associated with a decrease in an asset or an increase in a liability that can be measured reliably. Recognition
of expenses for the current period is made when revenue is accrued. An expense is recognized immediately in
the statement of comprehensive income when the expense does not create future economic benefits or when
and t o the extent that future economic benefits do not meet the requirements or cease to meet the requirements
for recognition of an asset in the statement of financial position . Expenses are accounted for on an accrual
basis and are comparable to recognized re venue. They are measured at the fair value of the remuneration paid
or pending for payment.
Expenses for future periods shall be deferred for recognition as current expenses in the period in which the
obligations under the contracts to which they refer, w o uld be performed.
Financial expenses consist of interest expenses and other direct costs related to loans as well as bank fees and
losses from foreign currency exchange .
2.11.3. Property, plant and equipment
Property, plant and equipment (non - current tangible as sets) are presented in the financial statements at
acquisition cost (cost price) less accumulated depreciation and impairment losses.
Initial evaluation
Upon initial acquisition, property, plant and equipment are e valu ated at acquisition cost (cost price), which
includes the purchase price, including customs charges and any directly attributable costs of bringing the asset
to working condition. The direct costs are as follows: costs of site preparation, costs of initial delivering and
handling, installation costs, costs for personnel remuneration fees related to the project, non - refundable taxes,

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 22 of 117
etc.
When acquiring property, plant and equipment on a deferr ed payment basis, the purchase price is equivalent
to the present value of the liability, discounted on the basis of the interest rate on the borrowed resources of
the company with a similar maturity and purpose. The difference between the cash price equiv alent and the
general payment is recognized as interest over the course of the loan unless it is capitalized in accordance with
IAS 23.
Evaluation after recognition
The approach chosen by the Group for the subsequent evaluation of property, plant and equip ment is the
acquisition cost model - less any subsequent depreciation and any accumulated impairment losses.
For all other classes of non - current tangible assets, the company has applied the acquisition cost model.
Depreciation Methods
The Company uses the straight - line method of depreciation of non - current tangible assets. Depreciation of
assets begins when they are available for use. The useful life by groups of assets is determined in accordance
with: physical wear and tear, specifics of the equipment, f uture intentions for use and actual obsolescence.
The useful life by classes of assets is as follows:
Vehicles 4 years
Computer equipment 2 - 5 years
Office equipment 3 - 6,67 years
Other non - current tangible assets 6,67 years
The determined useful life of non - current tangible assets is reviewed at the end of each year and, if significant
deviations are found against future expectations for the useful life of the assets, it is adjusted prospectively.
Write off of non - current tangibl e assets
The book value of an item of property, plant and equipment is written off : when it is sold, when no other
economic benefits are expected from its use, or when it is identified as missing .
Profits or losses arising on the write off of an item of property, plant and equipment are included in the
statement of comprehensive income when the asset is written off (unless IAS 17 requires otherwise in a sale
and leaseback). Profits and losses on dis posals of non - current assets are determined by deducting the book
value of the asset and the selling expenses from the proceeds from the sale (disposal). They are stated net, to
"Other operating income" in the statement of comprehensive income. The portion of the revaluation reserve
relating to the written off asset is transferred directly to retained earnings.
The receivable on disposal of an asset of property, plant and equipment is initially recognized at fair value.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 23 of 117
2.11.4. Intangible assets
Intangible assets are presented in the financial statements at acquisition price (cost price) less accumulated
depreciation and impairment losses. They include improvements to leased assets.
The Group applies a straight - line method of depreciation of intangible assets with a useful life of 2 years for
the software products, 6.67 years for the software platform, 3 years for an ISO certificate .
The book value of the intangible assets is reviewed for impairment when there are events or changes in
circumstances that indicate th at the book value amount could exceed their recoverable amount. Then the
impairment is included as an expense in the statement of comprehensive income .
Initial assessment
Externally generated intangible assets on their acquisition are evaluated at acquisition price , which includes
purchase price, import duties, non - refundable taxes and expenses of preparing the asset for its intended use.
The direct expenses are: expenses for preparation of the site (the place where the asset will be us ed), expenses
for initial delivery, installation expenses , expenses for fees of persons related to the project, non - refundable
taxes, etc.
Intangible assets are recognized if they meet the definition of intangible assets set out in IAS 38 Intangible
Assets , namely:
− Meets the definition of an intangible asset;
− Upon its acquisition it can be reliably assessed;
− Economic benefits are expected from the use of the asset, as evidenced by the availability or plan to
obtain sufficient resources to enable the enterprise to obtain the expected economic benefits; the
ability to effectively perform its functional role in accordance with the intention of the enterprise
regarding its use or there is a clearly defined and specified technical feasibility.
Subsequent e xpenses
Expenses related to the maintenance of initially established standard efficiency, incurred after the
commissioning of intangible non - current assets, are recognized as current at the time of their implementation.
The book value of the intangible ass et is adjusted to the extent of the expenses leading to the increase of the
expected future economic benefits associated with the use of an intangible asset over the initially determined
standard efficiency.
2.11.5. Goodwill
Goodwill is the excess of purchase pric es over the fair value of identifiable net assets of company acquires as
of the date of acquisition (business combination). Initially, it is presented in the consolidated financial
statements at acquisition cost and subsequently it is presented at acquisition cost minus impairment . Goodwill
is not amortized .

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 24 of 117
The goodwill generated as a result of the acquisition of a daughter company is presented in the consolidated
statement of financial position as a part of non - current assets a nd the goodwill generated as a result of
acquisition of joint - ventures or associated companies is included in the total value of investment and is reported
as “investments in associated companies”.
The goodwill associated with the acquisition of associated companies is tested as part of the total value of the
investment. The goodwill associated with the acquisition of daughter companies is tested for impairment at
least one per year. Losses recognized as a result of impairment of goodwill are not reversable . Profit or loss
from the sale of a daughter company include also book value of goodwill associated with this daughter
company .
Any goodwill amount recognized in the financial statements is attributable to a certain cash generating object
at the time a bus iness combination is completed, and this object is applied when tests for impairment are
conducted. For determining the cash - generating objects, are considered only objects that are expected to
generate future economic benefits and that are subject to the business combination, which generated the
goodwill.
Losses from impairment of goodwill are presented in the statements of comprehensive income as part of
“Impairment of non - current assets .
2.11.6. Other long - term capital investments
Other long - term financial inve stments are non - derivative financial assets in the form of shares and participation
of other companies (minority interest) held with a long - term perspective.
Initial valuation
Capital investments are initially recognized at acquisition cost, which is the fair value paid, including direct
acquisition cost of the investment (the financial asset). All purchases and sales of capital investments are
recognized on the “trading date” o f the transaction, i.e., the date on which the company commits to purchase
or sell the asset.
Subsequent e valuation
Capital investments owned by the Group are subsequently evaluated at fair value. The results of the subsequent
e valuation to fair value are presented in the statement of comprehensive income (in other components of
comprehensive income) and respectively in the reserve related to financial assets at fair value, through other
comprehensive income. These results are transferred to retained earnin gs on disposal (sale) of the respective
investment.
2.11.7. Investments in Associated companies
Investments in associated companies are reported following the capital method. The share of the Group in the
comprehensive income of an associated company is shown on o ne line in the consolidated statements in a way

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 25 of 117
that the amount of investment reflects the share of the Group in the net assets of the associated company as of
the date of the financial statements. The Group recognizes its share in the losses of an associ ated company up
to the amount of its investment, including all internal loans extended, unless it has undertaken an obligation to
pay such liabilities on behalf of the associated company.
As of 31.12.2021 t he Group reports a share in the profit of associated companies at the amount of BGN 32
thousand . The balance sheet amount of investments in associated companies was increased with the amount
of reported profit .
2.11.8. Non - current assets held for sale
Non - current assets are classified as held for sale if their book value will be recovered through sale rather than
through continuing use in the Company's operations. This condition is considered to exist only when the sale
is highly secure and the relevant non - current assets are available for immediate sale in their present condition.
Non - current assets classified as held for sale are measured at the lower value between the fair value and the
book value less the costs to sell.
2.11.9. Inventor ies
Inventories are accounted at the lower of the two following values : a cquisition cost (cost price) and net
realizable value.
The costs incurred to bring an inventory to its present condition and location are included in the cost of
acquisition (cost) as follows:
▪ Materials - the purchase price and all related costs of delivery;
▪ Goods - the purchase price and all related costs of delivery, customs duties, transport costs, non -
recoverable taxes and other costs incurred in order to bring the goods in ready for use state.
In the use (sale) of inventory, the first - in - first - out method is used.
2.11.10. Financial instruments
Financial assets
A financial instrument is any contract that gives rise to both a financial asset in one entity and a financial
liability or equity instrument in another enterprise.
Initial recogni tion, classification and evaluation
Upon initial recognition, financial assets are classified into three groups, according to which they are
subsequently assessed at depreciated value , at fair value through other comprehensive income and at fair value
thro ugh profit or loss.
The classification of financial assets upon initial recognition depends on the characteristics of the contractual
cash flows of the respective financial asset and the business model of the Company for its management.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 26 of 117
The business model of the Company for management of financial assets reflects how the Group manages its
financial assets to generate cash flows. The business model determines whether cash flows are the result of
contractual cash flows, the sale of financial assets, or both.
Evaluation
The Group initially presents financial assets at fair value, and in the case of financial assets that are not carried
at fair value through profit or loss, the direct transaction costs are added. An exception is trade receivables that
do not con tain a material financing component - they are estimated based on the transaction price determined
in accordance with IFRS 15 and the invoices issued.
Subsequent evaluation
For the purposes of Subsequent evaluation, financial assets are classified into four categories:
- Debt instruments presented at depreciated value
- Debt instruments presented at fair value through other comprehensive income (reclassified to profit
or loss);
- Capital instruments presented at fair value through other compreh ensive income (without
reclassification in profit or loss);
- Financial assets (debt instruments, capital instruments and derivatives) presented at fair value
through profit or loss.
During the current period, the Group reports financial assets in one of the se categories - financial assets at
depreciated value.
Financial assets at depreciated value (debt instruments)
This category is the most significant for the Group.
The Group measures financial assets at depreciated value when both of the following conditi ons are satisfied:
▪ the financial asset is held and used within a business model that aims to hold the asset in order to obtain
contractual cash flows from it, and
▪ the terms of the contract of the financial asset generate cash flows at specific dates, which represent
only principal payments and interest on the outstanding principal.
The management of the Group has assessed th e financial assets representing cash in banks, interest - bearing
receivables from related companies, trade receivables and other re ceivables (i.e., trade loans receivables and
others) are held by the Group in order to obtain the agreed cash flows and they are expected to result in cash
flows that represent solely principal and interest payments under the business model applied.
Finan cial assets at depreciated value are subsequently measured using the effective interest rate method (EIR).
They are subject to impairment. Profits and losses are recognized in the statement of comprehensive income
(in profit or loss for the year) when the asset is written off, modified or impaired.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 27 of 117
Write off
A financial asset is written off in the statement of financial position of the Group when:
▪ the rights to obtain cash flows from the asset have expired, or
▪ the rights to receive cash flows from the asset have been transferred or the Group has assumed an
obligation to pay in full the received cash flows, without significant delay, to a third party through an
agreement for transfer. In this case, the Group recognizes also the liability associated with it. The
transferred asset and the associated liability are measured on a basis that reflects the rights and
obligations that the Group has retained.
Continuing involvement, which is in the form of a guarantee on the transferred asset, is measured at the lo wer
of the two values: the initial book value of the asset and the maximum amount of consideration that the Group
may be required to pay.
Impairment of financial assets
The Group recognizes an adjustment (provision for impairment) for expected credit losse s on all debt
instruments that are not accounted at fair value through profit or loss. Expected credit losses are calculated as
the difference between the contractual cash flows payable under the terms of the contract and all the cash flows
that the Group expects to receive discounted at the initial effective interest rate.
At each accounting date, the Group determines whether the debt instrument is assessed as such with low credit
risk using all reasonable and well - grounded information that is available w ithout incurring unnecessary
expense or effort. In making this assessment, the Group reviews the internal credit rating of the debt
instrument. In addition, the Group assesses whether there is a significant increase in credit risk when
contractual payment s are overdue for more than 30 days.
The Group considers a financial instrument as default when contractual payments are overdue for more than
60 days. However, in certain cases, it may treat a financial asset as default when internal or external informati on
provides an indication that it is unlikely that the Group will receive the full amount of the outstanding
contractual amounts before taking into account any credit improvements held by it. Financial assets are written
off when there is no reasonable exp ectation for collection of contractual cash flows.
To calculate the expected credit losses of trade receivables and assets under contracts with customers , the
Group has chosen and applies a simplified matrix - based approach for calculating expected credit l osses and
does not track subsequent changes in their credit risk. In this approach, it recognizes an adjustment (provision
for impairment) based on the expected credit loss for the entire receivable period at each reporting date. The
Group has developed an d applies a provisioning matrix based on historical experience with respect to credit
losses, adjusted for prognostic factors, specific for the debtors and the economic environment, and correlated
with the percentage of credit losses. The collectability of receivables from related companies are assessed on
individual basis considering factors as financial needs of each related company and the business development

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 28 of 117
plan for the next periods.
Financial assets are written - off when there is no reasonable expecta tion of collection of contractual cash flows.
Financial liabilities
Initial recognition, classification and evaluation
Initially, all financial liabilities are recognized at fair value, and in the case of loans and borrowings and trade
and other payables, the net of directly related transaction costs.
Subsequent evaluation
Subsequent evaluation of financial liabilities depends on their classification as described below.
Financial liabilities evaluated at depreciation value
This category is essential for th e Group. Subsequent to their initial recognition, the Group evaluates interest -
bearing loans and borrowings at depreciation value using the effective interest method. Profits and losses are
recognized in the statement of comprehensive income (in profit or loss for the year) when the corresponding
financial liability is derecognized, as well as through depreciation at the effective interest rate method.
Depreciation value is calculated by taking into account any discounts or acquisition premiums, as well as fees
or expenses, which are an integral part of the effective interest rate. Depreciation is included as a “financial
expense” in the statement of comprehensive income (in profit or loss for the year).
Write off
Financial liabilities are written off when t he liability is repaid, terminated or expires. When an existing
financial liability is replaced by another of the same creditor under substantially different conditions, or the
terms of an existing liability are substantially altered, such exchange or modi fication shall be treated as
derecognition of the original liability and recognition of a new one. The difference with the book value of a
financial liability settled or transferred to another party in cash and/or non - monetary assets is recognized in
profi t or loss for the period.
2.11.11. Cash and cash equivalent
Cash includes cash on hand and amounts in current accounts, and cash equivalents are short - term deposits with
banks whose original maturity is less than 3 months.
The cash flow statement is presented using the direct method.
For the purpose of preparing the cash flow statement:
✓ Cash inflows from customers and cash payments to suppliers are presented gross, including VAT;
✓ VAT on purchases and sales of non - current assets is stated in the cash flows from operating activities,
to the extend it participates and is recovered in the operating cash flows of the Company for the relevant

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 29 of 117
accounting period.
✓ Interest on loans and deposits granted/received is included as inflows / payments to financi al activities.
Cash and cash equivalents are subsequently presented at depreciated value, without any accumulated
adjustments for expected credit losses.
2.11.12. Leasi ng
Operating lease
At the inception of the contract, the company assesses whether the contract re presents or contains a lease. A
contract represents or contains elements of a lease if, under that contract, the right to control the use of an asset
for a specified period of time is transferred in exchange for consideration. The assessment includes an
as sessment of the following factors:
▪ Whether the contract involves the use of an identified asset, this may be stated explicitly or by default,
and must be physically identifiable or must represent essentially the entire capacity of a physically
separate ass et. If the supplier has a substantial right of replacement, then the asset is not identified;
▪ Whether the company is entitled to receive substantially all the economic benefits from the use of the
asset throughout the useful life; and
▪ Whether the company h as the right to manage the use of the asset. The company has this right when it
has decision - making rights concerning the change in the manner and purpose of using the asset. In the
rare cases where it is predetermined how and for what purpose the asset wi ll be used, the company has
the right to manage the use of the asset if:
✓ The company has the right to operate the asset; or
✓ The company has designed the asset in a way that determines in advance how and for what purpose
it will be used
Financial leasing
The lease contract under which all risks and economic benefit of ownership of the asset are transferred to the
company of the Group is classified as a financial leasing and the leased asset is capitalized in the consolidated
statement of financial position of the lessee and presented as property, plant and equipment. Upon initial
recognition, leased assets are accounted at the lower value of the following two: their current fair value or the
present value of the minimum lease payments. The minimum lease payments are apportioned between the
finance expenses (interest) and the reduction of the lease liability (principal). Financial expenses are allocated
to each period over the lease term so that a constant interest rate is reached on the remaining ou tstanding
portion of the principal under the lease liability. Interest expenses are included in the consolidated statement
of comprehensive income as "Financial expenses".
Assets acquired under a financial leasing are depreciated based on the useful life o f the asset and within the

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 30 of 117
lease term.
2.11.13. Provisions
Provisions are recognized when the Group has a present (constructive or legal) obligation as a result of a past
event, and it is probable that an outflow of resources will be required to settle the obligation. Provisions are
estimated on the basis of the best estimate of the management at the da te of preparation of the financial
statements for the expenses necessary for the settlement of the respective obligation. The estimate is discounted
when the maturity of the liability is long - term. When it is expected that part of the resources that will b e used
to settle the obligation will be recovered from a third party, the company recognizes a receivable, if there is a
high degree of certainty of its receipt, its value can be reliably determined as income (credit) on the same
position in the Statement of Comprehensive Income, where the provision itself is presented.
The Group accrues provisions for guarantee service of devices sold. The provision is calculated on the basis
of best estimate of management about the expected expenses, which the Group will incur in case of guarantee
events and based on the past experience about the sold products/ services. As of the date of the consolidated
financial statements, the management estimated the provision for guarantee services to be 0,5% of net revenue
from sale of goods and production, generated from clients outside the group of Allterco.
2.11.14. Liabilities to employees
Defined contribution plans
The government of the Republic of Bulgaria undertakes the liability to ensure pension payments on the basis
of defined contr ibution plans. The liability of the Company to pay the amounts booked under the defined
contribution plans for the employees is recognized the in statement of comprehensive income at the time of
o ccurrence of the liability.
Paid annual leave
The Group recognize as a liability undiscounted amount of estimated cost of annual paid leave, which is
expected to be paid to employees in return to their labor for the past reporting period.
Defined income for retirement
In compliance with the Labor Code, when a labor contract of an employee that obtained the right for pension
is terminated, the Company pays a compensation at the amount of two gross monthly salaries, if the employee
worked for the Company less than 10 years, or six gross monthly salaries if the em ployee worked for the
Company more than 10 years. The Group estimates that the amount is not significant and therefore it is not
included in the financial report.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 31 of 117
2.11.15. Share capital
The Group has adopted the financial concept of maintaining the capital. The financial capital maintaining is
assessed in nominal monetary units. Profit for the reporting period is considered to be acquired only if the total
equity amount at the end of the period exceeds the amount in the beginning of the period, after deducting the
distributions to owners or their investments in capital during the period.
Allterco JSCo is a joint - stock company and is obliged to register in the Commercial Register its statutory share
capital, which shall serve as a security for its cred itors. The shareholders are responsible for the liabilities of
the mother - c ompany up to the amount of their shareholding in the capital and may claim the return of that
holding only in case of bankruptcy or liquidation proceedings. The mother - company repor ts it registered
capital at par value of the number of shares registered.
Equity is the residual value of an entity's assets after deducting all its liabilities. This includes:
Registered capital – it is presented in the Statement of financial position acc ording to the number of issued
shares with nominal value of each share.
Financial result – it is formed as the difference between the income and expenses accrued for it . This includes:
a) retained earnings;
b) uncovered loss;
c) the net profit or loss for the current year, which is presented in the statement of financial position after
deduction of tax expense due.
The Equity is decreased by the dividends paid to the shareholders during the period in which they are
distributed (voted by the General Meeting).
In accordance with the requirements of the Commercial Law and the Statute of Allterco JSCo ., the company
is obliged to form reserves at the expense of:
− at least one - tenth of the annual profit, until the funds accumulated reach 25 per cent of the share
capital;
− the funds received above the nominal value of the shares issued (premium reserve);
Treasury shares are reported in the statements of financial position at acquisition cost, which is used to decrease
the equity of the Group. T he profit and losses from the sale of treasury shares are reported in the equity of the
Group, as part of the retained earnings.
During the reporting period the company has made payments to the employees of its Bulgarian subsidiaries in
shares.
The payment in shares against labor services is made with owner’s equity instruments of the mother - company.
The equity instruments are valued at fair value as of the date of share transfer. The expense related to the

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 32 of 117
payment in shares is recognized for the period in which the services were rendered.
Reserve from translation of financial statement of foreign operations - arises from the net effects of foreign
currency conversion of the subsidiaries ’ financial statements from their functional currencies into Bulgarian
l evs for the purpose of consolidation.
Other comprehensive income is formed by the difference between previous book value of financial assets
reported at fair value and the fair value of such assets as of the date of the report.
Treasury shares are presented in the financial statements at fair value as of the date of th e statements and are
reported as a decrease in the shareholder’s equity . Profits and losses from the sale of treasury shares are
reported directly in the shareholder’s equity.
2.11.16. Income tax expenses
Income tax expense represents the sum of the current income taxes and the tax effect on temporary tax
differences. The c urrent income tax is determined in accordance with the tax legislation of the respective
country . The nominal corporate profit tax rate in Bulgaria for 2021 and 2020 is 10%.
The foreign daughter companies are subject to corporate profit tax in accordance with the local legislation.
The applicable tax rates are as follows:
Country Nominal tax rate
2021 2020
Singapore 17 % 17 %
Malaysia Up to MYR 500 000 - 20%
and for the excess - 25%
Up to MYR 500 000 - 20%
and for the excess - 25%
USA 15 - 35% 15 - 35 %
Thailand 20 % 20 %
Germany 15,825% n/a
Deferred tax assets and / or liabilities are the amounts of recoverable and payable income taxes for future
periods in respect of deductible and taxable temporary tax differences.
Temporary tax differences are established by comparing the book value of an asset or liability presented in the
Statement of financial position with its tax base when applying the tax rules.
Deferred income taxes are calculated using the balance sheet liability method. Deferred tax liabilities are
calculated and recognized for all taxable temporary differences, while deferred tax assets are recognized only
if it is probable that they will be recovered and if the company will be able to generate sufficient profit in the
future from which they to be deducted.
The effect of recognizing the deferred tax assets and / or liabilities is reflected where the effect of the event
that gave rise to them is presented.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 33 of 117
Fo r events that affect the statement of profit or loss and other comprehensive income, the effect of deferred
tax assets and liabilities is also recognized in the statement of comprehensive income.
For events that are initially reported in equity (revaluatio n reserve) and deferred tax assets and liabilities are
recognized at the expense of equity.
In the Statement of financial position, deferred tax assets and / or liabilities are presented as compensation, as
they are subject to a single taxation regime.
As of December 31, 2021 and December 31, 2020 the Group recognize deferred corporate profit taxes only
for the Bulgarian companies and they are estimated using 10% rate, which remains unchanged for 2022.
2.11.17. Earnings per share
The basic earnings per share are calculated by dividing the net profit or loss for the period that is subject to
distribution among shareholders of ordinary shares, by the average weighted number of ordinary shares held
during the period.
The weighted average number of shares represents t he number of ordinary shares hold in the beginning of the
period, adjusted by the number of repurchased ordinary shares and the new issued shares during the period
multiplied by a time - weighting factor. This factor represents the number of days in which sp ecific shares have
been held relative to the total number of days in the period.
Earning of shares with reduced value should not be calculated because there are no shares with reduced value
issued.
2.11.18. Judgments that are crucial in applying accounting policie s of the Group.
Key high uncertainty estimates and assumptions .
In the process of applying accounting policies, the management of the Group makes judgments that have a
material effect on these financial statements. Such judgments by definition are rarely equal to actual results.
As a result of their nature, they are subject to constant review and updating and include historical experience
and other factors as expectations for future events that management believes are reasonable in the current
circumstan ces.
The estimates and assumptions that carry a significant risk of a material adjustment in the carrying amounts of
assets and liabilities in the next financial year are set out below.
Useful life of property, plant and equipment and intangible assets
Th e financial statements of property, plant and equipment and intangible assets include the use of estimates of
their useful lives and carrying values, which are based on judgments made by the management of the Group .

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 34 of 117
Impairment of receivables
The Management estimates the amount and timing of expected future cash flows related to receivables based on
experience in current circumstances in the following groups: individual accounts, households and other small
consumers and legal receivables . Due to t he inherent uncertainty of this assessment, the actual results may differ
from those expected. The management of the Group reviews the estimates from previous years against the actual
results from the previous year.
In connection with the implementation of IFRS 9 Financial Instruments, the Group have used their accumulated
experience in the area of credit losses, and have taken into account current conditions and their forecasts to
estimate the expected credit losses on their trade receivables.
2.11.19. Fair value s
Fair value is the price that could be obtained from the sale of an asset or could be paid for the transfer of a liability
in the ordinary course of trade between market participants at the date of assessment (starting price). Fair value
assessment is base d on the assumption that the transaction to sell an asset or transfer a liability has been carried
out:
▪ on the principal market of the respective asset or liability, or
▪ in the absence of a principal market, on the most advantageous market for the asset or liability.
The principal or the most advantageous market should be accessible for the Company.
The fair value of an asset or liability is estimated by making the assumptions that market participants would make
when establishing the price of the asset or li ability, assuming that they act in their best economic interest.
All assets and liabilities that are measured at fair value or for which fair value disclosure is required in the financial
statements, are grouped into categories according to the fair value hierarchy, as described below, based on the
lowest level of input data used, which has a significant impact on fair value measurement in general:
• Level 1 - quoted (unadjusted) prices in active markets for identical assets or liabilities are used
• Level 2 - appraisal methods are applied in which the lowest level of used input data essential for fair value
assessment have been observed either directly or indirectly
• Level 3 - appraisal techniques are used where the lowest level of used input data essential for fair value
assessment are unobserved
For the assets and liabilities that are regularly evaluated at fair value the Company shall review their categorization
at the appropriate level of the fair value hierarchy (based on the lowest level of us ed input data, that have a
significant impact on the fair value evaluation as a whole) to the end of the reporting period and determine whether
the re is a need to make a transfer (s) from one level to another.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 35 of 117
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
3. Notes to the consolidated statement of financial position
3.01. Property, plant and equipment
Lands Buildings Facilities Machinery
and
equipment
Vehicles Computer
equipment
Office
equipme
nt
Other Expenses
for
acquisition
of fixed
tangible
assets
Total
January 01, 2020
Acquisition cost 465 3 123 131 719 503 226 126 151 86 5 537
Accumulated depreciation - (209) (16) (236) (201) (117) (89) (110) - (985)
Book value 465 2 914 115 483 302 109 37 41 86 4 552
Acquisitions 1 011 148 - 9 - 14 2 9 62 1 255
Purchase 1 011 - - 9 - 14 2 9 62 1 107
Put into operation - 148 - - - - - - - 148
Disposals - - - - (19) - - - (148) (167)
Sale - - - - (12) - - - - (12)
Put into operation - - - - - - - - (148) (148)
Other way - - - - (7) - - - - (7)
Depreciation for the
period
- (122) (39) (216) (116) (66) (8) (6) - (573)
Changes in depreciation - 239 - - 13 - - - - 252
Depreciation of written off
assets
- 239 - - 13 - - - - 252
Book value as of 1 476 2 940 76 276 167 57 31 44 - 5 067
December 31, 2020
Acquisition cost 1 476 3 032 131 728 471 240 128 160 - 6 373
Accumulated depreciation - (92) (55) (452) (304) (183) (97) (116) - (1 306)
Book value 1 476 2 940 76 276 167 57 31 44 - 5 067
Assets held for sale 3 2 5
Book value at the end 1 476 2 940 76 276 167 54 29 44 - 5 062
January 01, 2021
Acquisition cost 1 476 3 032 131 728 458 240 128 151 9 6 353
Accumulated depreciation - (92) (55) (452) (291) (183) (97) (116) - (1 286)
Book value 1 476 2 940 76 276 167 57 31 35 9 5 067
Acquisitions - - - 53 - 24 58 142 46 323
Purchase - - - 53 - 24 58 142 46 323
Decrease (book value) - - - - (3) (3) (45) - - (51)
Disposals - - - - - - (43) - - (43)
Other way - - - - (3) - - - - (3)
Written off book value
related to sold investments (3) (2) - - (5)
Depreciation for the
period - (121) (39) (217) (94) (49) (8) (13) - (541)
Changes in depreciation - - - - 3 4 84 51 - 142
Depreciation of written off
assets - - - - 3 4 84 51 - 142
December 31, 2021
Acquisition cost 1 476 3 032 131 781 452 257 57 242 55 6 483
Accumulated depreciation - (213) (94) (669) (382) (228) (21) (78) - (1 685)
Book value at the end 1 476 2 819 37 112 70 29 36 164 55 4 798
The land and building owned by the Group are pledged in relation with bank financing used for their purchase ( see
point 3.1 5 ) .

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 36 of 117
3.02. Intangible assets
Softwa re ISO certificates
and intellectual
property rights
T rademarks and
prototypes
Others Capitalized
R&D e xpenses
Total
January 01, 2020
Acquisition cost 190 871 1 661 212 1 929 4 863
Accumulated amortization (116) (164) (481) (14) - (775)
Book value 74 707 1 180 198 1 929 4 088
Acquisitions - 3 1 427 - 3 027 4 457
Purchase - 3 - - 638 641
Capitalized - - - - 2 389 2 389
Put into operation - - 1 427 - - 1 427
Disposals - - (271) - (3 421) (3 692)
Put into operation - - - - (3 161) (3 161)
Other way - - (271 ) - (260) (531)
Amortization for the period (74) (80) (270 ) (20) - (444)
Changes in Amortization - - 126 - - 126
Amortization of written off assets - - 126 - - 126
Book value - 630 2 066 178 1 535 4 409
December 31, 2020
Acquisition cost 190 874 2 691 212 1 535 5 502
Accumulated amortization (190) (244) (625) (34) - (1 093)
Book value - 630 2 066 178 1 535 4 409
Assets held for sale - 625 141 766
Book value - 5 2 066 37 1 535 3 643
January 01, 2021
Acquisition cost 190 874 2 691 212 1 535 5 502
Accumulated amortization (190) (244) (625) (34) - (1 093)
Book value - 630 2 066 178 1 535 4 409
Acquisitions 141 5 1 767 - 2 285 4 198
Purchase 6 5 11 - - 22
Capitalized - - - - 2 285 2 285
Put into operation 135 - 1 756 - - 1 891
Disposals - (625) (546) (141) (3 695) (5 007)
Written off book value of assets
related to sold investments - (625) - (141) - (766 )
Other way - - (546) - (3 695) (4 241)
Amortization for the period (17) (3) (456) (8) - (484 )
Changes in amortization - 242 298 14 - 554
Amortization of written off assets - - 298 - - 298
Written off amortization of assets
related to sold investments - 242 - 14 - 256
Book value as of the end 124 7 2 831 29 125 3 116
December 31 , 2021
Acquisition cost 331 12 3 614 57 125 4 139
Accumulated amortization (207) (5) (783) (28) - (1 023)
Book value 124 7 2 831 29 125 3 116

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 37 of 117
3.03. Assets with right of use
2021 2020
Vehicles Buildings Total Vehicles Buildings Total
In the beginning of the period
Acquisition cost 127 9 136 127 9 136
Amortization (84) (6) (90) (42) (3) (1 235)
Book value 43 3 46 85 6 (1 099)
Acquisitions 116 - 116 - - -
Operating leasing 116 - 116 - - -
Disposals (11) - (11) - - -
Written off (11) - (11) - - -
Amortization for the period (40) (3) (43) (42) (3) (45)
Book value at the end of the period
Acquisition cost 232 9 241 127 9 136
Amortization (124) (9) (133) (84) (6) (90)
Book value 108 - 108 43 3 46
The Group has concluded lease agreements for renting office spaces and vehicles used in its activity. The terms
are between 1 and 4 years with extension options.
3.04. Goodwill
Name December 31 , 202 1 December 31,
20 20
Allterco Robotics Inc., USA 34 34
Allterco Sdn, Malaysia - 30
Allterco PTE Ltd, Singapore - 2 611
Allterco Properties EOOD (Solely - owned LLC) 126 126
Total: 160 2 801
Impairment of goodwill
The management of the Croup has undertaken the necessary procedures to perform the mandatory impairment
test of the goodwill recognized in the consolidated statement of financial position for the acquisition of the
subsidiaries. For this purpose, it is assumed that each individual co mpany appears as a "cash - generating unit".
The calculations are made by the management, based on a detailed review of whether events and facts have
occurred, which are indicators of changes in the assumptions and estimates made as of December 31, 2020
and December 31 , 20 21 .
As a result of the analyses performed by the Group's management as of December 31, 2020, an impairment of
the reported goodwill of the Asian subsidiaries in the amount of BGN 480 thousand was recognized. No
impairment of goodwill is rec ognized as of December 31 , 2021.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 38 of 117
3.05. Investments in associated companies
During 2021 Allterco participated in the establishment of a new company in China – Allterco Asia Ltd. , with
seat and management address Shenzhen, Guangdong Province . The registered capital of the new company is
CNY 100 000 as Allterco holds 30% (8 thousand B GN) and has an option to acquire additional up to 50%,
reaching up to 80%, if the develop ment of the company meets the expectations of Allterco .
The movement of the investments in associated companies is as follows:
December 31,
2021
Opening balance at Jan 1 -
Acquisition of participation in the capital 8
Share in the profit for the period 32
Balance as of December 31 40
3.06. Other long - term capital investments
December 31 ,
202 1
December 31,
20 20
Ordinary registered shares – Link Mobility , in the
beginning of the period 6 566 3 053
Increase - 4 849
Reserves from subsequent evaluation of financial
instruments - 4 849
Decrease (3 942) (1 336)
Effect from transactions with financial assets ( 369 ) (1 336)
Revaluation of other financial instrument s ( 3573) -
Ordinary registered shares – Link Mobility , at the end
of the period 2 624 6 566
3.07. Long - term trade receivables
I n September 20201 the Company sold its investments in A llterco PTE, Singapore , A llterco SDN Malaysia
and A llterco C o . LTD Thailand . In compliance with the requirements of IFRS 5 Non - current assets Held for
Sale and Discontinued Operations as of December 31, 2020 those assets are presented as held for immediate
sale. The terms of the sale contract stipulate that 50% of the purchase price at the amount of 1 050 thousand
EUR (2 054 thousand BGN) is due after 2022 (525 thousand EUR (1 027 thousand BGN) is due in 18 months
after the date of the deal and the remaining 535 thousand EUR (1 027 thousand BGN) is due in 36 months
after the date of the deal). Because of this, the receivable related to the sale of the daughter companies which
is due after 2022 is shown as long - term receivable.
The management assess that the value of other long - term receivables presented in the statement of financial
position as of December 31, 202 1 is equal to their fair value.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 39 of 117
3.08. Deferred tax assets
December 31 ,
2021
December 31,
2020
Deferred tax assets
Accruals for unused leave 19 18
Provisions for liabilities 3 0 25
Impairment of receivables 2 5 438
Depreciation - 1
Unpaid remuneration - 3
Total deferred tax assets 74 485
Deferred tax liabilities
Depreciation ( 2 ) -
Total deferred tax liabilities ( 2 ) -
Total deferred tax asset (liability) 72 485
3.09. Inventor ies
December 31 ,
2021
December 31,
2020
Goods 3 900 3 592
Supplies 2 227 -
Goods in transit 979 -
Materials 454 68
Total: 7 560 3 660
As of December 31, 2021 in the consolidated statement of financial position are presented:
- Components for production of devices at the amount of 2 227 thousand BGN, which were ordered by
the Group and purchased by the factories that produce devices for the Group. The components are
available at the warehouse of the factories and according to the agreement s the Group has ownership
rights over them
- Goods in transit, which are not in the warehouses of the Group yet but which are owned by the Group
on the basis of purchase agreeme n ts
The Group policy is to try to maintain optimal quantity of goods equal to a several months forecast of sales.
The management of the Group expects that in the near future the level of inventories will continue to
increase as a consequence of increasing sale s as well as a result of increasing deficit of certain electronic
components ne cessary for the production of devices.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 40 of 117
3.10. Trade receivables
December 31 ,
2021
December 31,
2020
Receivables from customers 12 642 9 504
Advances to suppliers 6 762 5 759
Trade receivables associated to assets held for sale - (954)
Advances to suppliers associated to assets held for sale - (361)
Impairment of receivables (237) -
Total 19 167 13 948
The management made an assessment for impairment of a receivable related to the sale of its European telecom
business, which was due in August 2021 and as of December 31, 2021 it was still unpaid. The management
stared a procedure for collection of the re ceivable following the provisions of the share purchase agreement
signed , which provides for initiation of an arbitrage proceedings in front of the International Arbitrage in
Vienna. The impairment recognized for this receivable is at the amount of 152 tho usand BGN (5% of due
amount). One of the group companies recognized an impairment of receivable ate the amount of 85 thousand
BGN (50% of the receivable from EDS Ltd., Serbia ) .
Ageing analysis of gross value of trade receivables is presented in the table b elow:
December 31,
2021
December 31,
2020
Current 9 220 10 447
Overdue up to 90 days 7 129 3 501
Overdue up to 180 days 3 055 -
Overdue up to 360 days - -
Overdue up to 360 days - -
Total 19 404 13 948
The management of the Group believes that the value of trade receivables presented in the consolidated
statements of financial position is equal to their fair value as of December 31, 2021 and December 31, 2020.
3.11. Other receivables
December 31 ,
2021
December 31,
2020
TAX RECEIVABLES 1 884 629
Overpaid c orporate profit tax 2 280
VAT refund receivable 1 857 295
Customs duties 25 54
Withholding tax - 473
Assets held for sale - (473)
OTHER RECEIVABLES 28 80
Receivables on litigations - 55
Advances to employees 4 3

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 41 of 117
Deposits with companies and guarantees 22 14
Other receivables 2 60
Assets held for sale - (52)
Total: 1 912 709
3.12. Cash and cash equivalents
December 31 ,
2021 December 31, 2020
Cash on hand 92 43
Cash in current accounts 30 320 25 950
Other cash - debit cards 4 2
Restricted cash (guarantees) 125 125
Assets held for sale - (70)
Total: 30 541 26 050
By currency
December 31 ,
2021 December 31, 2020
BGN 13 298 15 121
EUR 6 180 10 542
USD 11 063 387
Total 30 541 26 050
The Group's cash funds are in bank accounts with banks with stable long - term ratings. The Management has
assessed the expected credit losses on cash funds and cash equivalents. The estimated value is determined as
insignificant and is not accrued in the consolidated financial statements of the Group as of December 31 , 202 1
3.13. Prepaid expenses
December 31 , 202 1 December 31 , 20 20
Up to
one year
Over one
year Total Up to
one year
Over one
year Total
Operating activity
Insurances 35 - 35 3 - 3
Information Services 28 - 28 1 - 1
Subscriptions 27 - 27 - - -
Memberships 34 - 34 - - -
Trade fairs 109 - 109 - - -
Other 1 - 1 38 - 38
Total operating activity 234 - 234 42 - 42
3.14. Non - current assets classified as held for sale and assets included in disposal groups classified as
held for sale
During 2019 the Group's management decided to sell is subsidiaries : Allterco PTE Singapore, Allterco SDN
Malaysia, and Allterco Co. Thailand . In accordance with the requirements of IFRS 5 Non - current assets held
for sale in the accompanying consolidated fi nancial statements for 2020 the assets, related liabilities and

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 42 of 117
financial results are presented as subject to immediate sale.
During 2021, Allterco JSCo. has finalized a deal with Skylight Venture Capital Pte. Ltd., Singapore for the
sale of 3 subsidiarie s with the following terms:
▪ Sales price: 2 100 000 EUR;
▪ Payment terms: i. 50 % - after signing the SPA and the Buyer issues a letter to the Seller that all
conditions for completion of the deal are met; ii. 25 % - within 18 after completion; iii. 25 % - within
36 months after completion.
▪ Collateral: first priority pledge of the shares of the capital of ALLTERCO PTE (Singapore) and
ALLTERCO SND (Malaysia) in favor of ALLTERCO JSCo to secure the obligation of Skylight
Venture Capital Pte. Ltd. for the diffe red payment of 50 % of the purchase price.
Following the sale of the 3 subsidiaries the Group reports a profit at the amount of BGN 201 thousand, shown
in the statements of comprehensive income as financial income.
3.15. Bank loans
Then depreciable portion of bank loans is as follows :
December 31 , 2021 December 31,
2020
Raiffeisenbank AD, including: 1 900 2 176
- up to one year 285 276
- over one year 1 615 1 900
DSK bank EAD 617 843
- up to one year 225 225
- over one year 392 618
Other short - term financing Allterco Robotics USA 6 2 10
Total bank loans - non - current portion: 2 007 2 518
Total bank loans - current portion: 57 2 511
Bank Raiffeisenbank AD
Date of the contract : August 25 , 2017
Agreed loan amount : 1 620 000
Original currency EUR
Purpose
Financing up to 90% (excluding VAT) of the final price of all company shares
representing 100% of the capital of the joint debtor Allterco Properties EOOD
(Solely - owned LLC), designated in the concluded between the Borrower and JFC
Developments OOD (Ltd.) Share Transfer Contract into Final Contract
Term May 10 , 2029
Collaterals :
Mortgage on real estate, owned by
Allterco Properties EOOD (Solely - owned LLC), joint debtor -
Allterco Properties EOOD (Solely - owned LLC), pledge of all bank accounts of
Allterco JSCo . with the bank

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 43 of 117
Creditor DSK Bank AD
Date of the contract: September 28 , 2020
Total amount EUR 450 thousand
Purpose Financing of 90% of the expenses for purchase of real estate
Currency EUR
Fixed term September 28 , 2024
Collaterals: Mortgage of real estate owned by Allterco Properties Ltd.
3.16. Lease
December 31 , 202 1 December 31 , 20 20
Up to
one year
Over one
year Total Up to
one year
Over one
year Total
Finance lease liabilities 31 - 31 29 31 60
Operating lease liabilities 27 80 107 46 46
Lease liabilities 58 80 138 75 31 106
Liabilities under lease agreements presented in the consolidated statement of financial position include the
liabilities of the Group under rental agreements for offices and vehicles, which are recognized in accordance
with the requirements of IFRS 16 Leasing .
The reconciliation of movements in liabilities related to financing activities (current and non - current) is
presented in the next table
Type of financing Book value
as of
Net cash
flow
Interest Non cash
movements
Book value
as of
1.1.2021 31.12.2021
Bank loans 3 029 ( 526 ) ( 76 ) - 2 579
Leasing contracts 106 30 ( 2 ) - 138
3.17. Trade payables
December 31 ,
202 1
December 31,
20 20
Suppliers 931 2 943
Advances from clients 556 881
Liabilities related to assets held for sale - (2 437)
Total: 1 487 1 387
3.18. Payables to employees
December 31 ,
2021
December 31,
2020
Payables to employees 5 130
Payables for unused paid leave 168 151

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 44 of 117
Liabilities related to assets intended for sale - (87)
Total: 173 194
3.19. T a x liabilities
December 31 ,
2021
December 31,
2020
Corporate tax 281 283
Value Added Ta x 940 156
Income tax 73 38
Other taxes 21 26
Liabilities related to assets held for sale - (108)
Total: 1 315 395
3.20. Other liabilities
December 31 ,
2021
December 31,
2020
Liabilities for purchase of shares 665 675
Guarantees/deposits for rent 61 90
Guarantee service provision 300 250
Other liabilities - 3
Liabilities related to assets held for sale - (3)
Total other liabilities 1 026 1 015
3.21. Registered capital
Allterco JSCo was registered in 2010. The registered capital of the Company as of December 31, 202 1 amounts
to BGN 1 7 , 999 , 999 ( seventeen million nine hundred ninety - nine thousand nine hundred ninety - nine ) and is
distributed in 1 7 , 999 , 999 ( seventeen million nine hundred ninety - nine thousand nine hundred ninety - nine )
ordinary registered shares with a nominal value of BGN 1 each. The registered capital is fully paid in four
installments:
The first issue was made upon the establishment of the Company in the form of a non - monetary contribution
in the amount of BGN 50 000, which had as its subject ordinary registered voting shares of the capital of
Teravoice AD .
In 2010 a second non - monetary contribution was made in the amoun t of BGN 5 438 000, which had as its
subject shares from the capital of Tera Communications AD .
At the end of 2015, a new issue of 8,012,000 (eight million and twelve thousand) ordinary registered voting
shares was issued, with a nominal value of BGN 1 (on e) each.
At the end of 2016 the capital of ALLTERCO JSCo was increased with a new issue in the amount of 1,500,000
(one million and five hundred thousand) shares on the basis of a successful initial public offering, according
to the Prospectus for public o ffering of shares, confirmed by the Financial Supervision Commission with

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 45 of 117
Decision No 487 – Е of July 08 , 2016 entered in the Commercial Register under No.20161108100414 of
November 08 , 2016.
In 2020 the capital of the Company was increased by cash contribu tions in the total amount of 2,999,999 (two
million nine hundred ninety - nine thousand nine hundred and ninety - nine) against 2,999,999 (two million nine
hundred ninety - nine thousand nine hundred and ninety - nine) subscribed and paid dematerialized ordinary
r egistered voting shares with a nominal value of BGN 1 as a result of a procedure for Public Offering of a new
issue of shares. The public offering of shares from the capital increase of Allterco JSCo was carried out in the
period September 28, 2020 – Octob er 30, 2020 on the basis of a Prospectus, together with the supplements to
it, confirmed by the Financial Supervision Commission with Decision No 148 - F of February 18, 2020,
Decision No 405 - E of June 11, 2020, Decision No 601 - E of August 13, 2020 and Decisio n No 791 - E of October
29, 2020.
As of December 31 , 202 1 the shareholders in the company are:
Name Number of
shares: % in the capital
Svetlin Todorov 5 847 120 32.48%
Dimitar Todorov 5 847 120 32.48%
Persons holding 5% of the capital
Other physical persons and legal entities 6 305 759 35 . 04 %
Total 17 999 999 100.00%
3.22. Retained earnings
December 31 ,
2021
December 31,
2020
Opening balance 26 938 13 531
Net profit (of owners of the parent - company) 15 962 15 141
Profit (Loss) for the period from discontinued operations - (1 284)
Distribution of dividends (3 600) (450)
Change due to sale of subsidiaries 94 -
Retained earnings 39 394 26 938
3.23. Reserves
December 31 ,
2021
December 31,
2020
Opening balance 1 500 1 500
Reserve from issue of shares 300 -
Total: 1 800 1 500
3.24. Reserve from issue of shares
As of December 31. 2021 the reserves from issue of shares are at the amount of 5 403 thousand BGN. They
are formed by the excess of share price of newly issued shares during 2020 ove r the par value of shares. The

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 46 of 117
excess amount was 6 000 thousand BGN and was decreased by the expenses related to the share issue at the
amount of 2967 t housand BGN and by 300 thousand BGN, which were transferred to reserves, pursuant to a
decision of the g eneral meeting of shareholders held on June 28, 2021 .
3.25. Other comprehensive income
December 31,
2021
December 31,
2020
Value at the beginning of the period 4 849 -
Reserves transferred to retained earnings (240) -
Reserves related to long - term financial instruments reported at
fair value (3 573) 4 849
Value at the end of the period 1 036 4 849
The reserves re l ated to the long - term financial instruments decreased by 3 573 thousand BGN as a result of
the revaluation of the long - term financial instruments held at fair value and by 240 thousand BGN as a result
of transfer of reserves to retained e a r n ings, after the sale of pa rt of financial instruments.
4. Notes to the consolidated statement of comprehensive income
4.01. Sales revenue and cost price of sales
2021 2020
Production Goods Services
and rents Total: Produc
tion Goods Services
and rents Total:
Sales revenues 108 58 723 678 59 509 639 38 478 7 225 46 342
Cost of goods sold - (24 964) - (24 964) - (15 444) - (15 444)
Other direct costs - (1 525) (233) (1 758) (265) ( 1 822 ) (7 117) ( 9 204 )
Cost of sales - (26 489) (233) (26 722) (265) ( 17 266 ) (7 117) ( 24 648 )
Gross profit 108 32 234 445 32 787 374 21 212 108 21 694
4.02. Other operating income
202 1 2020
Loss from sale of fixed assets (23) (4)
Rents 2 12
Written off liabilities 40 23
Insurance indemnity 26
Interests 8 -
Revaluation of financial instruments 246 -
Penalties 6 16
Financing - 589
Exchange rate differences gains 1 006 240
Other operating income 187 137
Total: 1 498 1 013

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 47 of 117
4.03. Administrative expenses
2021 2020
Material expense 190 131
External services 2 408 1 377
Depreciation 193 353
Salaries and social security 7 590 6 115
Other administrative expenses 1 789 723
Total: 12 170 8 699
During 2021 the Bulgarian subsidiaries provided to some of the ir employees, which meet certain criteria set
by the management of the Group, additional payments in shares, which do not carry any restrictions for
further disposition. The total number of shares transferred to the employees was 14 018 shares with par value
of BGN 1 each and market price at the date of the transfer BGN 24,40 per share. The value of services
provided by the employees was calculated using the tin last closing share price at Bulgarian Stock Exchange
before the date of share transfer. The paymen t in shares is done entirely with treasury shares.
Also, at the end of 2021 the group companies reviewed their capitalized costs related to development of
product prototypes and the ongoing projects related to product development . As a result of this revie w, the
group companies write off prototypes and product development costs at the amount of 1 331 thousand BGN.
The agreed fees for the independent financial audits of the Group for 2021 is at the total amount of 32 thousand
BGN (2020 – 31 thousand BGN ). During the year the auditors did not provide tax advice or any other services
to the Group. The current disclosure is compliance with Art. 30 of the Accounting Act.
4.04. Other operating expenses
2021 2020
Bank fees 134 124
Written off receivables 97 -
Impairment of receivables 85 483
Interest and penalties 28 27
Provision for guarantee service 300 250
Donations 15 37
Other 54 194
Total: 713 1 115
The movement of provision for guarantee is as follows:
December 31, 2021 December 31, 2020
Provision for guarantee liabilities in the beginning of the period 250 -
Accrued for the period 300 250
Used provision during the period (250) -
Provision for guarantee liability at the end of the period 300 250

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 48 of 117
4.05. Financial income
2021 2020
Gains from operations with financial assets, including 250 3 446
- Sale of shares 4 526 4 949
- Book Value of shares sold (4 276) (1 336)
- Expenses related to the sale of shares - (167)
4.06. Financial expenses
2021 2020
Currency exchange rates losses 140 739
Interest on financial lease 2 6
Interest on loans 76 84
Bank fees on cash balances 45 20
Other interest 3 -
Total: 266 849
4.07. Tax expenses
December 31,
2021
December 31,
2020
Profit before tax 18 722 14 948
Tax at applicable tax rate (1 872) (1 495)
Effect from deferred tax (52) 215
Adjustment on the effect of deferr e d tax as a result of
consolidation (836) (230)
Corporate tax Income /( Expense ) (2 760) (1 510)
Corporate tax income (expenses) as of December 31, 2021 г. is comprised of the following components :
December 31,
2021
December 31,
2020
Current tax expense (2 347) (1 576)
Net effect from deferred tax (413) 66
Corporate tax Income /( Expense ) (2 760) (1 510)

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 49 of 117
5. Contingent liabilities and commitments
Contract Annex Creditor Debtor Joint debtor
/Guarantor
Amount/Li
mit
Financial
conditions Term
COLLATERAL
provided by the
borrower
Investment loan
August 25,
2017
contract under
art. 114 para 10
of the Public
Offering of
Securities Act
Annex
No.1
October
31, 2018
Raiffeisen
bank
Bulgaria
EAD
Allterco
JSCo
Allterco
Properties
EOOD -
solidary
1 620 000
EUR
Fixed interest
rate for the
whole period
3% per year;
Management
fee
May 10,
2029
Mortgage on real
estate owned by
Allterco
Properties
EOOD;
Pledge of
receivables on
bank accounts
with the bank.
Pledge under the
law for financial
security
contracts;
Overdraft
September 30,
2019 – contract
under art. 114
para 10 of the
Public Offering
of Securities
Act
Annex
No.1 of
August
28, 2020
Raiffeisen
bank
Bulgaria
EAD
Allterco
Robotics
EOOD
Allterco JSCo -
guarantor
1 000 000
EUR
One - month
EURIBOR,
+ 2.5 % , but
not less than
2.5%;
management
commission;
commitment
commission;
commission
for issuing
guarantees;
Septembe
r 29, 2022
Pledge of
receivables on
accounts;
Contract for
standard
investment loan
No.2757 dated
September 28,
2020
none DSK
Bank AD
Allterco
Properties
EOOD
Allterco
Trading EOOD
– solidary
debtor
450 000
EUR
Annual
interest rate
formed by a
variable
interest rate
of 1m
EURIBOR +
2.1% but not
less than
2.1%; annual
management
fee;
Septembe
r 28, 2024
Mortgage on real
estate owned by
Allterco
Properties
EOOD; Pledge
of receivables on
bank accounts of
Allterco
Pr operties
EOOD and
Allterco Trading
EOOD in DSK
Bank.
In relation to the signed in 2019 contract for sale of five subsidiaries , the Buyer did not pay the last
installment of the purchase price at the amount of 3 053 thousand BGN in accordance with the agreed
payment schedule. The management of Allterco take the necessary actions, as per the terms of the signed
Share Purchase Agreement, though opening and arbitration case in the International Arbitration of Vienna .
6. Transactions with related parties
Key management remuneration
The key management of the Group includes the Executive directors and the members of the Board of Directors.
The remuneration of the key management for the reporting period was as follows :

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 50 of 117
20 21 2020
Short - term remuneration - -
Salaries 971 691
Total 971 691
The companies included in the Group are disclosed in item 1. 3 . During the reporting period the Group did not
engage in transactions with its shareholders or entities , which c ould be considered as related parties.
7. Financial instruments by category
The accounting policies for financial instruments are applied to the items listed below
Structure of financial assets and liabilities by categories is as follows :
December 31 , 2021
Financial assets according to the
Statement of financial position Cash
Financial
assets reported
at depreciated
value
Financial assets
reported at fair
value through
other
comprehensive
income
Financial
assets
reported at
fair value
through profit
or loss
Total
Cash and cash equivalents 30 541 - - - 30 541
Other long term financial assets - - 2 624 - 2 624
Non - current trade receivables - 2 054 - - 2 054
Current trade receivables 12 405 - - 12 405
Deposits and guarantees 22 - - 22
TOTAL FINANCIAL ASSETS 30 541 14 481 2 624 - 47 646
December 31 , 2021
Financial liabilities according to the
Statement of financial position
Financial
liabilities
reported at a
specifically
determined value
Financial
liabilities
reported at fair
value through
profit or loss
Total
Financial
liabilities
reported at
depreciated
value
Leas ing 138 - - 138
Bank loans 2 579 - - 2 579
Trade liabilities 931 - - 931
Liabilities for purchase of shares 665 - - 665
Guarantees 61 - - 61
Other liabilities - - - -
TOTAL FINANCIAL LIABILITIES 4 374 - - 4 374
December 31, 2020
Financial assets according to the
Statement of financial position Cash
Financial
assets
reported at
depreciated
value
Financial
assets
reported at
fair value
through other
comprehensive
income
Financial
assets
reported at
fair value
through profit
or loss
Total
Other long term financial assets - - 6 566 - 6 566
Cash and cash equivalents 26 050 - - - 26 050

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 51 of 117
Trade receivables - 8 550 - - 8 550
Deposits and guarantees - 14 - - 14
TOTAL FINANCIAL ASSETS 26 050 8 564 6 566 - 41 180
December 31, 2020
Financial liabilities according to the
Statement of financial position
Financial
liabilities
reported at
depreciated value
Financial liabilities
reported at a
specific ally
determined value
Financial
liabilities
reported at fair
value through
profit or loss
Total
Lease 106 - - 106
Bank loans 3 029 - - 3 029
Trade liabilities 756 - - 756
Liabilities for purchase of shares 675 - - 675
Guarantees 90 - - 90
TOTAL FINANCIAL LIABILITIES 4 656 - - 4 656
8. Financial risk management
In the course of their normal business, the Group companies may be exposed to various financial risks, the
most significant of which are: market risk (currency risk, risk of changes in fair value and price risk), credit
risk, liquidity risk and interest ra te risk. The general financial risk management is focused on forecasting the
changes in the financial markets to minimize potential adverse effects on financial performance. Financial
risks are currently identified, measured and monitored through various c ontrol mechanisms to determine
adequate measures and to avoid unjustified exposure to any potential financial risk.
Financial risk management is an ongoing process direct ly supervised by the management of the Group and
financial experts . It is carried in accordance with a policy established by the Board of Directors of the Parent -
company, which has developed the basic principles of general financial risk management . O n the basis of those
principals specific procedures for managing the individual specific financial risks are define d.
The various types of financial risks to which Group companies are exposed in the course of their business
operations are described below, as well as the approach taken to mitigate them.
Market Risk
а. Currency risk
Th e Group companies carry out their transactions in Bulgaria, some in the European Union and others in third
countries (Asia and USA ). The biggest portion of supplies made by the Group companies are in Bulgarian lev
(BGN), Euro and US dollars. In order to co ntrol the currency risk, a system for planning the supplies from
countries inside and outside the European Union is used , as well as procedures for periodic monitoring of
movements in exchange rates of foreign currencies and control of forthcoming payments.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 52 of 117
The tables below summarize the exposure to currency exchange rates:
December 31 , 2021
in EUR in USD
in another
foreign
currency
in BGN T otal
Cash and cash equivalents 6 180 11 063 - 13 298 30 541
Non - current trade receivables 2 054 - - - 2 054
Current trade receivables 10 036 1 344 419 606 12 405
Deposits - 11 - 11 22
TOTAL ASSETS 18 270 12 418 419 13 915 45 022
Lease 18 - - 120 138
Bank loans 2 517 62 - - 2 579
Trade payables 370 68 - 493 931
Liabilities for purchase of shares - - - 665 665
Guarantees - - - 61 61
TOTAL LIABILITIES 2 905 130 - 1 339 4 374
31 December 2020
in EUR in USD
In other
foreign
currency
In BGN Total
BGN'000 BGN'000 BGN'000 BGN'000 BGN'000
Trade receivables 7 698 97 - 755 8 550
Cash and cash equivalents 10 542 387 - 15 121 26 050
Deposits - - - 14 14
TOTAL ASSETS 18 240 484 - 15 890 34 614
Bank loans 843 10 - 2 176 3 029
Leasing - - - 106 106
Trade liabilities 291 111 - 354 756
Liabilities related to purchase of
shares - - - 675 675
Guarantees - - - 90 90
TOTAL LIABILITIES 1 134 121 - 3 401 4 656
Currency sensitivity analysis
The Group companies are not exposed to foreign currency risk with respect to their euro transactions.
Currency risk is associated mainly to payments in US dollars and Norwegian krone (NOK) . As of December
31 , 20 21 , 27.58 % of the Group's current financial assets are in US D and 0.93 % in NOK .
b. Price risk
The Group companies are exposed to a specific price risk with respect to the prices of the services provided
and goods sold . Minimizing the price risk of negative changes in prices is achieved by periodically analyzing
and renegotiating contractual terms in order to update prices in the light of market changes.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 53 of 117
Allterco JSCo. owns shares of Link Mobility Group that are traded on a regulated market. During the year the
Company sold part of its shares and reported profit from the transaction. The remaining shares are exposed to
price risk.
Risk of interest - bearing cash flows
There is no significant concentration of interest - bearing assets in the Group companies, except for loans
granted and free cash on current accounts with banks. For this reason, the operating cash flows are to a great
extend independent of changes in market interest rates.
At the same time, the cash outflows of the Group companies for the reporting period are exposed to interest
rate risk due to the use of bank loans in EUR agreed at a variable interest rate.
Cash in current accounts with banks is subject to interest at interest rates according to the tariffs of the
respective banks.
The exposure of the Group companies to changes in market interest rates is constantly monitored and analyzed .
Different scenarios of refinancing, renewal of existing interest rat es and alternative financing are simulated.
The calculations cover significant interest - bearing positions.
December 31 , 2021
interest - free
with floating
interest rate
%
with fixed
interest
rate %
T otal
BGN'000 BGN'000 BGN'000 BGN'000
C ash and cash equivalents 30 541 - - 30 541
Current trade receivables 12 405 - - 12 405
Non - current trade receivables 2 054 - - 2 054
Deposits 22 - - 22
TOTAL ASSETS 45 022 - - 45 022
Lease - - 138 138
Bank loans - 679 1 900 2 579
Trade payables 931 - - 931
Liabilities for purchase of shares 665 - - 665
Guarantees 61 - - 61
TOTAL LIABILITIES 1 657 679 2 038 4 374
December 31, 2020
interest - free
with
floating
interest rate
%
with fixed
interest
rate %
T otal
BGN'000 BGN'000 BGN'000 BGN'000
Trade receivables 8 550 - - 8 550
Cash and cash equivalents 26 050 - - 26 050
Deposits 14 - - 14
TOTAL ASSETS 34 614 - - 34 614
Bank loans - 853 2 176 3 029
Leasing - - 106 106
Trade liabilities 756 - - 756
Liabilities related to purchase of shares 675 - - 675

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 54 of 117
Guarantees 90 - - 90
TOTAL LIABILITIES 1 521 853 2 282 4 656
Credit Risk
The financial assets of the Group companies are concentrated mainly in two groups - cash (cash on hand and
in bank accounts) and receivables from clients .
Credit risk is basically the risk that the customers of the Group companies will not be able to pay the due
amounts in full and in the usual terms. Receivables from cus tomers are presented in the c onsolidated statement
of financial position at fair value. An impairment for doubtful and difficult - to - collect receivables has been
accrued, based on previous experience with events leading to losses from un collectability .
The Group companies do not have a significant concentration of credit risk. Their policy is to negotiate a credit
period longer than 60 days only with customers that have a long trading history and cooperation with the Group
companies. Payments from customers are made by bank transfer s .
Significant part of Group's revenue is generated by mobile operators or other client , which in most cases are
large companies with very good credit ratings.
The collectability and concentration of trade receivables is monitored on an ongoing basis, in accordance with
the established policy of the Group companies. For this purpose, regularly the Finance and Accounting
Departments review the open positions by customers and receipts, and make an analysis of outstanding
amounts.
As o f December 31 , 202 1 cash and banks transfers are allocated to several banks, which mitigates the risk
related to cash and cash equivalents exposure .
Liquidity Risk
Liquidity risk is the risk that the companies face difficulties in meeting their financial obligations . Part of the
Group customers are mobile operators or other big companies that have a very good credit rating and meet
their payment deadlines.
The Group companies maintain a conservative liquidity management policy aimed at constantly maintaining
an optimum cash reserve and the ability to finance their business. They also use some borrowed credit
resources.
To control liquidity risk, the Group companies co ntrol the timely payment of liabilities in accordance with the
agreed payment terms with each client .
The Group companies monitor and control the actual and forecas ted cash flows and try to match the maturities
of assets and liabilities. On an ongoing basi s the maturity and timely payment are monitored by accounting
department and daily information on available cash and the obligations for future payments is maintained .

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 55 of 117
December 31 ,
2021
up to 1
month
1 - 3
months
3 - 6
months
6 - 12
months 1 - 2 years 2 - 5 years
over 5
years
with no
maturity total
BGN'000 BGN'000 BGN'000 BGN'000 BGN'000 BGN'000 BGN'000 BGN'000 BGN'000
Cash and cash
equivalents 125 - - - - - - 30 416 30 541
Current trade
receivables 9 048 455 - 2 902 - - - - 12 405
Non - current
trade receivables - - - - 1 027 1 027 - - 2 054
Deposits - - - - - - - 22 22
TOTAL
ASSETS 9 173 455 - 2 902 1 027 1 027 - 30 438 45 022
Lease liabilities 3 7 10 38 27 53 - - 138
Bank loans 48 109 158 256 523 1 103 382 - 2 579
Trade payables 839 17 25 50 - - - - 931
Liabilities for
purchase of
shares 10 20 30 605 - - - - 665
Guarantees - - - - - - - 61 61
TOTAL
LIABILITIES 900 153 223 949 550 1 156 382 61 4 374
31 December 2020
up to 1
month
1 - 3
months
3 - 6
months
6 - 12
months
1 - 2
years
2 - 5
years
over 5
years
with no
maturit
y total
BGN'000 BGN'000 BGN'000 BGN'000 BGN'000 BGN'000 BGN'000 BGN'000 BGN'000
Trade receivables 3 434 1 962 99 3 055 - - - - 8 550
Cash and cash
equivalents - - 125 - - - - 25 925 26 050
Deposits - - - - - - - 14 14
TOTAL ASSETS 3 434 1 962 224 3 055 - - - 25 925 34 614
Bank loans 42 83 148 228 511 1 497 520 - 3 029
Leasing 5 16 16 7 26 36 - - 106
Trade liabilities 680 76 - - - - - - 756
Liabilities related to
purchase of shares
- - - - 675 - - - 675
Guarantees - - - 90 - - - - 90
TOTAL
LIABILITIES
727 175 164 325 1 212 1 533 520 - 4 656
Capital risk management
With the capital manageme nt the Parent Company aims to create and maintain the ability for continuous
operat ions ( going concern company) and to ensure the appropriate return on investment to shareholders, as
well as to maintain optimal capital structure in order to reduce capital costs.
A l lterco JSCo monitors its capital structure using the debt ratio. It is calculated as the ratio between the net
debt capital and the total amount of capital. Net debt is defined as the difference between all borrowings
(current and non - current) as stated in the c onsolidated s tatement of f inancial p osition and cash and cash
equivalents. The total amount of capital is equal to the equity and the net debt capital.
The table below presents the debt ratios based on the capital structure as of:

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 56 of 117
December 31 , 2021 December 31, 20 20
Total debt capital, incl.: 6 833 8 857
- Bank loans 2 579 3 029
- Lease liabilities 138 106
Reduced by cash and cash equivalents 30 541 26 050
Net debt capital (23 708) (17 193)
Total equity 65 540 56 836
Total capital 41 832 39 643
Ratios of indebtedness 0.00% 0.00%
The G roup is no t in debt for the reporting periods , as cash exceeds the total debt capital.
9. Fair value
Usually, external independent appraisers are used for the assessment of fair value of significant assets. The
need of external appraisers is assessed annually by the management of the Company. External appraisers are
chosen based on their professional experience, qualities and reputation.
The Group's policy is to disclose in its financial statements the fair value of financial assets and liabilities for
which information about market prices is available .
For the purpose of fair value disclosure, the Company determines different classes of a ssets and liabilities,
depending on their nature, characteristics and risk, and on the relevant level in the fair value hierarchy set out
in Significant Accounting Policies.
The Company's management has estimated that the fair values of cash and cash equiv alents, trade receivables,
trade payables, finance lease and bank loans are close to their book values due to the short - term nature of these
instruments and their timely payment over time.
The table below shows the book value and fair value of financial as sets and liabilities, including their levels in
the value hierarchy. Fair value information is not presented if the book value is considered reasonably equal
to the fair value.
December 31 , 2021 Book value Level 1 Level 2 Level 3
Financial assets
Cash and cash equivalents 30 541 - - -
Current trade receivables 12 405 - - -
Other long term financial investments 2 624 2 624 - -
Non - current trade receivables 2 054 - - -
Deposits 22 - - -
TOTAL ASSETS 47 646 2 624 - -
Financial liabilities
Lease 138 - -
Bank loans 2 579 - 2 545 -
Trade payables 931 - - -

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 57 of 117
Liabilities for purchase of shares 665 - - -
Guarantees 61 - - -
Other liabilities 0 - - -
TOTAL LIABILITIES 4 374 - 2 545 -
December 31, 2020
Book value Level 1 Level 2 Level 3
Financial assets
Other long term financial investments 6 566 6 566 - -
Cash and cash equivalents 26 050 - - -
Trade receivables 8 550 - - -
Deposits in companies and guarantees 14 - - -
TOTAL ASSETS 41 180 6 566 - -
Financial liabilities
Lease 106 - - -
Bank loans 3 029 - 2 578 -
Trade payables 756 - - -
Liabilities for purchase of shares 675 - - -
Guarantees 90 - - -
Other liabilities 0 - - -
TOTAL LIABILITIES 4 656 - 2 578 -
During 2020 a transfer has been made of long - term investments in shares from Level 3 to Level 1 on the ground
that the shares have been registered for trade o n a regulated stock exchange. No transfers have been made
during the reporting period.
10. Events after the end of reporting period
The following impor tant events , which are considered non - adjusting, occurred after the end of the reporting
period :
10.1 Extraordinary General meeting of shareholders
The Company has announced to the FSC and to the Public the following information:
We hereby inform you that at its extraordinary session held on 08.04.2022, the General Meeting of
Shareholders of Allterco JSCo adopted the following resolutions:
1. The General Meeting of the Shareholders increased the number of the members of the Board of
Directors from 3 to 5, where the General Meeting of the Shareholders confirms the current members of
the Board of Directors and appoints, in addition, the following new members: Mr. Wolfgang Kirsch
and Mr. Gregor Bieler
2. The General Meeting of Shareholders approved amendments to the Remuneration Policy
3. The General Meeting of Shareholders approved amendments and supplements to the Statute of the

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 58 of 117
Company
4. The General Meeting of Shareholders approved the remuneration, the management guarantee and
the compensation of the ne w Board Members
5. The General Meeting of the Shareholders approved the terms and conditions for buyback of up to
80,000 own shares until 31 December 2022 at price in the rage from BGN 15 to BGN 30 per share.
The buyback can be done at once or in part in one or several buyback procedures (until the maximum
number of shares is reached) by the Company and/or any of its subsidiaries through an investment
intermediary from any shareholder through stock exchange and/or OTC transactions. The Board of
Directors i s authorized to undertake all other specific parameters of the buyback and to take all
necessary legal and factual actions in execution of this resolution of the General Meeting of
Shareholders
The Company will publish the minutes of the General Meeting w ithin the legally established period.
Some of the decisions are subject to entry in the Commercial Register and the Register of Non - Profit Legal
Entities.
In compliance with the decision of the General Meeting of the Shareholders and the Statute of the Company,
the Board of Directors has appointed Mr. Wolfgang Kirsch and Mr. Dimitar Dimitrov as Chief Executive
Officers of the Allterco JSCo in a later meeting held the same day (8 April 2022) .
In compliance with the decisions taken by the general meeting of shareholders, during the first meeting of the
new Board of Directors, carried on April 8, 2022, the following appointments were made:
• Gregor Bieler - Chairmen ;
• Nikolay Martinov – Deputy Chairmen ;
• Dimitar Dimitrov – Executive Director and representative ;
• Wolfgang Kirsch – Executive Director and representative ;
• Svetlin Todorov – Member and representative ;
The representative members of the Board of Directors represent the company jointly or separately .
For further information, please visit w w. allterco.com
10.2 Military conflict between Russia and Ukraine
In February 2022, following the start of military conflict between Russia and Ukraine, some countries
announced new packages of sanctions against the sovereign debt of Russian Federation, a number of Russian
banks and a number of Russian citizens.
As a result of increasing geopolitical tension, a significant volatility of some financial markets , and in
particular, the depreciation of Russian ruble against USD and EUR is observed since February 2022. It is
expected that those events will affect the activities of the Russian and Ukrainian companies in different
economic sectors

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
EXPLANATORY NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS
AS OF DEC EMBER 3 1 , 20 2 1
Unless otherwise stated, all amounts are in BGN thousand.
Page 59 of 117
The Group is not exposed directly, or through related parties, or through key clients and suppliers, to t he
countries involved in the conflict.
The Group considered this event as non - adjusting event after the end of the reporting period the effect of which
cannot be assessed at this time with an acceptable level of accuracy.
The management is analyzing the po ssible impact of the changing micro and macroeconomic conditions on
the financial and operating results of the Group .
10.3 Change in the fair value of long - term financial investments
Allterco JSCo. owns long - term investments in financial instruments (share s of Link Mobility Group Holding
ASA), which are traded on a regulated market. After the date of current financial statements, a drop in the
price of those financial instruments is observed, which, to some extent, according to the management of the
Group , is due to the overall negative trend of financial markets as a consequence of the military conflict in
Ukraine.
The management monitors the financial performance of Link Mobility Group Holding and believes that the
drop in its share price is temporary. In this context the event is considered as a non - adjusting event after the
end of reporting period.
10.4 Allterco Robotic Ltd. capital increase
On March 14, 2022, t he board of directors of Allterco JSCo decided to increase the capital of its wholly owned
subs idiary Allterco Robotics Ltd. The goal of the capital increase is to accelerate the development of new
products, to increase the production capabilities and finance the entrance to new markets.
The registered capital of Allterco Robotics was increased from the current level of BGN 1 500 000 to BGN 7
000 000 by issuing new 5 500 000 shares at par value of BGN 1,00 each. The whole new emission was
subscribed by Allterco JSCo and was funded entirely with own funds.
10.5 Goods in transit
As of the date of the current financial statements all goods in transit, presented in note 3.09 above arrived at
the warehouses of the Group.
10.6 Preliminary data on consolidated sales revenue for Q1 2022
On April 14, 2022 t he Group announce d preliminary data about the consolidated sales revenue for the first
quarter of 2022. The data show 26.2% year - to - year increase in consolidated revenue from sales of devices
(including related services) to BGN 17.4 million (EUR 8.9 million). While the revenue from sales of Shelly -
bra nded smart home devices increased by 25.1%, amounting to BGN 16.6 million (EUR 8.5 million), the
revenue from sales of MyKi tracking devices decreased by 8.7% to BGN 447 thousand (EUR 229 thousand),
showing trend of recovery mainly as a result of the phasi ng out the anti - pandemic measures taken by the
governments of a number of countries where the devices are being sold.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
Page 60 of 117
CONSOLIDATED ANNUAL REPORT
ON THE BUSINESS ACTIVITIES OF
ALLTERCO JSCo
FOR FINANCIAL YEAR 2021
THIS BUSINESS ACTIVITY REPORT IS PREPARED IN ACCORDANCE WITH THE PROVISIONS OF ART. 39 ET SEQ.
FROM THE ACCOUNTING ACT, ART. 100N, PARAGRAPH 7 OF THE PUBLIC OFFERING OF SECURITIES ACT AND
ANNEXES No 2 OF ORDINANCE No 2 DATED 9 NOVEMBER 2021 ON PROSPECTUSES FOR PUBLIC OFFERING AND
ADMISSION TO TRADING ON A REGULATED SECURITIES MARKET AND DISCLOSURE OF INFORMATION.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
Page 61 of 117
DEAR SHAREHOLDERS,
We, the members of the Board of Directors of ALLTERCO JSCo., committed to manage the company in the best interest
of the shareholders, as well as on the basis of the requirements of the provisions of Art. 39 et seq. of the Accounting Act
(in force since 01.01.2016), Art. 100n, Paragraph 7 of the Public Offering of Securities Act and Annex No. 2 of Ordinance
No. 2 of 9 November 2021 on prospectuses for public offering and admission to trading on a regulated securities market
and for disclosure of informati on, have prepared this activity report (hereinafter "The Report"). The Report provides
comments and analysis of the financial statements and other material information regarding the financial position and the
results achieved by the company operations. The report contains an objective review that presents truthfully and honestly
the development and performance of ALLTERCO JSCo, as well as its status, together with a description of the main risks
it faces.
The circumstances that occurred in 2021, which the c ompany's management believes may be of significance to the
investors in deciding to acquire, sell or continue to hold publicly offered securities, have been disclosed within the time
limits provided for in the Public Offering of Securities Act and by the F inancial Supervision Commission, investors and
the regulated securities market.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
Page 62 of 117
This Report on the activity of Allterco JSCo presents information about the company on a consolidated basis as of 31
December 2021 and covers the period 01.01.2021 - 31.12.2021 (“reporting period”).
I. GENERAL INFORMATION ABOUT THE COMPANY
ALLTERCO JSCo is a public limited company with the following main business activity: Acquisition, management,
evaluation and sale of participations in Bulgarian and foreign companies; acquisition, management and sale of bonds;
acquisition, evaluation, sale and assignment of licenses for the use of patents and other intellectual and industrial propert y
rights; financing of c ompanies in which the Company participates; purchase of goods and other goods for resale in the
raw, processed or treated form; sale of goods from own production; foreign trade transactions; commissions, forwarding,
warehousing and leasing transactions; tr ansport transactions in the country and abroad; transactions of commercial
representation and mediation of local and foreign individuals and legal entities; consultancy and marketing transactions;
providing management and administration services to local a nd foreign legal entities; as well as any other commercial
transactions not prohibited by the law.
The Company was entered in the Commercial Register on 11 February 2010.
As of 31.12.2020 ALLTERCO JSCo has its registered office, telephone, fax, e - mail, w eb site as follows:
• Current registered office as of the date of preparing this Report on address: City of Sofia 1407, 103 Cherni Vrah
Blvd
• Tel: +359 2 9571248
• e - mail: investors@allterco.com
• Web page: www.allterco.com
As of the end of the reporting period, the issued, subscribed, paid up and registered capital of the Company amounts to
BGN 17 999 999 (seventeen million nine hundred and ninety - nine thousand nine hundred and ninety - nine leva), divided
into17 999 999 (seventeen million nine hu ndred and ninety - nine thousand nine hundred and ninety - nine) dematerialized
ordinary registered voting shares with par value of 1 (one) BGN for each share.
The share capital was fully paid in by five contributions:
• Contribution in kind representing 100% o f the shares of Teravoice EAD (Solely - owned PLC), with a monetary
valuation of BGN 50 000 (fifty thousand leva);
• Contribution in kind representing 69.60% of the shares of Tera Communications AD (PLC), with a monetary
valuation of BGN 5 438 000 (five milli on four hundred and thirty - eight thousand leva);
• A combination of contributions in kind and monetary contributions worth BGN 8 012 000 (eight million and
twelve thousand leva).
• Cash contributions with a total value of BGN 1 500 000 (one million and five hundred thousand leva) against
subscribed and paid 1 500 000 (one million and five hundred thousand) dematerialized ordinary registered voting
shares with a par value of 1 BGN as a result of a procedure for initial public offering of a new issue of shares.
• Cash contributions with a total value of BGN 2 999 999 (two million nine hundred and ninety - nine thousand
nine hundred and ninety - nine leva) against subscribed and paid 2,999,999 (two million nine hundred and ninety -
nine thousand nine hundred and ninety - n ine) dematerialized ordinary registered voting shares with a par value

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
Page 63 of 117
of 1 BGN as a result of a procedure for initial public offering of a new issue of shares. The public offering of
shares from the capital increase of Allterco JSCo was held in the period 28.09.2020 – 30.10.2020 on the basis of
a Prospectus together with its supplements as affirmed by the Financial Supervision Commission with Ordinance
No 148 - Е of 18.02.2020, Decision No 405 - Е of 11.06.2020, Decision No 601 - Е of 13.08.2020 and Decision No
791 - Е of 29.10.2020.
As of 31 December 2020, the capital structure of ALLTERCO JSCo is as follows:
SHAREHOLDER NAME PERCENTAGE OF THE
CAPITAL
Svetlin Todorov 32.48 %
Dimitar Dimitrov 32.48 %
Other individuals and legal entities 35.04 %
1. In - kind contributions have been made in the last three financial years
In the last three financial years, no in - kind contributions have been made to the company's capital.
2. Information about the issuer's management system
As of 31.12.2021, ALLTERCO JSCo has a one - tier management system - 3 - member Board of Directors, according to a
resolution of the General Meeting of Shareholders dated 20.12.2020, entered in the Commercial Register under No.
20210105090633
As of 31.12.2021, the members of the Board of Directors are:
• Dimitar Stoyanov Dimitrov
• Svetlin Iliev Todorov
• Nikolay Angelov Martinov
As of the end of the reporting period, there has been a change in the composition of the Board of Directors, with the
resolution of the General Meeting of Shareholders of 08.04.2022 changing the number of the Board members from three
to five, where Mr. Wolfgang Kirsch and Mr. Gregor Bieler join to the current members.
Pursuant to the resolution of the General Meeting of Shareholders at it s first meeting held on 08.04.2022. t he Board of
Directors elects from among its members the following executive members, Chairman and Deputy - Chairman:
• Gregor Bieler - Chairman;
• Nikolay Martinov - Deputy Chairman;
• Dimitar Dimitrov - Executive Director and Representative;
• Wolfgang Kirsch - Executive Director and Representative;
• Svetlin Todorov - Member of the Board of Directors and Representative;
II. REVIEW OF THE COMPANY’S BUSINESS ACTIVITY AND STATUS
As of 31.12.2021, Allterco JSCo reports investments in t he following companies:
- 100% of the capital of Allterco Robotics EOOD, Bulgaria;
- 100% of the capital of Allterco Properties EOOD;
- 100% of the capital of Allterco Trading EOOD
- 100 % of the capital of Allterco Robotics US (previously named Global Teracomm In c., (DBA Allterco
Robotics);

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
Page 64 of 117
- 100 % of the capital of Allterco Europe GmbH;
During the reporting period Allterco JSCo has participated in the establishment of a company (associated company) in
China, Allterco Asia Ltd. 91440300MA5GMK2T5B, with domicile and registered office: number 716, Building A,
XingHe Shiji, Cai Tian road 306 9, Gangxia, Futian, Shenzhen, Guangdong Province China. The capital of the new
company is CNY 100 000, as the participation of Allterco JSCo is 30% with an option to acquire additional up to 50%
and reach a controlling stake of up to 80% in case of good de velopment of the project.
During the reporting period there was change in the economic group of Allterco JSCo:
- On September 27,2021 the Board of Directors of Allterco JSCo has approved and the Company, as a seller, has
signed with Skylight Venture Capital Pte. Ltd., as a buyer, an agreement for the sale of the participations of
Allterco JSCo in the subsidiaries ALLTERCO PTE (Singapore), ALLTERCO SDN (Malaysia) and ALLTERCO
Co., Ltd. (Thailand) ( Share Purchase Agreement (SPA). The transfer of the share owne rship is a subject to
registration procedures in accordance with applicable laws in each country where each company is registered as
a legal entity.
- Allterco JSCo has founded a subsidiary in Germany – Allterco Europe GmbH. The German Company has its
seat a nd registered office in Munich, Germany and capital of EUR 500 000, 100 % held by Allterco JSCo.
III. RESULTS FROM THE ACTIVITY
1. FINANCIAL RESULT
As of the end of the reporting period, ALLTERCO JSCo reported on a consolidated basis a net profit at the amount of
BGN 15 962 thousand, compared to the net profit of BGN 13 439 thousand for 2020, and BGN 7 305 thousand for 2019.
The increase of the profi t in 2021 compared to 2020 is mainly due to dividends at the amount of BGN 5 million received
from a subsidiary company and the realized profit from operation with financial instruments in the amount of BGN 250
thousand. The profit in 2020 and 2019 is also to a great extent influenced by the realized profit from sale of financial
instruments.
Table No 1
EQUITY 12/31/2019 % 12/31/2020 % 12/31/2021
Registered capital 15000 20% 18 000 0% 18 000
Retained earnings 13 531 99% 26 938 46% 39 394
Legal reserves 1 500 0% 1 500 20% 1 800
Reserves from issue of shares - - 5 703 - 5.26% 5 403
Treasury shares - - ( 138 ) - 100.00% -
Other comprehensive income - - 4849 - 79% 1036
Exchange differences 182 54% 280 - 122% - 61
Non - controlling interests 123 - 341% ( 296 ) - 100% -
TOTAL 30 336 87.35% 56 836 15.37% 65 572
In 2021 the Company records a decrease in other comprehensive income , which is mainly due to revaluation of financial
assets that are presented at fair value in the statement of financial position

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
Page 65 of 117
Revenue from ordinary business activity
Table No 2
REVENUE 2019 change 2020 change 2021
Thousand
BGN %
Thousand
BGN %
Thousand
BGN
Sale of goods and production 21 039 85.9% 39 117 50.4% 58 831
Revenue from services and rents 12 279 - 41.2% 7 225 - 90.6% 678
Other operating revenue 182 456.6% 1 013 47.9% 1 498
Total operating revenue 33 500 41.4% 47 355 28.8% 61 007
Gain from operation s with financial assets 8475 - 59.3% 3 446 - 92.7% 250
Total financial income 8475 - 59 .3 % 3 446 - 9 2.7 % 250
As of the end of the reporting period, ALLTERCO JSCo does not report revenue from sale of goods , services and
production on a consolidated basis compared to the previous one . In the same time the revenue from services and rents
decreased by 90,6% which is mainly due to the telco business.
As of the end of 2021 the Company reports gains from operations with financial instruments, which include:
- BGN 49 thousand from sale of shares of Link Mobility Group
- BGN 201 thousand from the sale of its participation in 3 subsidiaries;
Operating expenses by economic elements
Table No 3
EXPENSES 2019 change 2020 change 2021
Thousand
BGN %
Thousand
BGN %
Thousand
BGN
Materials 862 - 84.8% 131 45.0% 190
External services 2 102 - 34.5% 1 377 74.9% 2 408
Depreciation 819 - 56.9% 353 - 45.3% 193
Salaries 3 294 85.6% 6 115 24.1% 7 590
Other administrative expenses 678 6.6 % 73 3 147.4 % 1 789
Sales and marketing 428 26.6% 542 397.4% 2 696
Other operating expenses 5 603 - 8 0.1 % 1 115 - 36.1 % 713
Total Operating Expenses 13 786 - 24.9% 10 356 50.4% 15 579
As of the end of the reporting period the total operating expenses of ALLTERCO JSCo increased by 50,4 % compared
to the previous year. This increase is mainly due to the increase of marketing and sales expenses , which increased by
397 .4% , the expenses for salaries and social securities, which increased by 24.1% and the expenses for external services
which increased by 74.9% .
The external services hold the biggest share in the total operating expenses for salaries and social securit ies with 48. 7 %,
followed by the expenses for marketing and sales 17.3 % and the expenses for external services with 15,5%.

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Unified Identification Code (UIC): 201047670
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FINANCIAL INDICATORS
2. LIQUIDITY
Table No 4
LIQUIDITY RATIOS 12/31/2019 12/31/2020 12/31/2021
Current ratio 3.21 7.47 12.52
Quick ratio 3.02 6.88 10.93
Immediate liquidity ratio 1.58 4.13 6.44
Cash ratio 2.36 6.34 10.47
The total liquidity ratio at the end of the reporting period in creased due to the following: the current assets in creased
by 26.2 % compared to the end of 2020, while the current liabilities de creased by 24.8 %.
The quick liquidity ratio at the end of the reporting period in creased due to the following: the inventories in creased
by 106.9 % compared to the end of 2020, while the current liabilities de creased by 24.8 %.
The immediate liquidity ratio at the end of the reporting period increased due to the following: the current liabilities
de creased by 24.8 % compar ed to the end of 2020, while cash in creased by 17.2 %.
The cash rat io at the end of the reporting period in creased due to the following: The current liabilities de creased by
24.8 % compared to the end of 2020, while the cash increased by 17.2 % and the short - term financial assets have been sold
during the reporting period.
0.00
2.00
4.00
6.00
8.00
10.00
12.00
14.00
Current ratio Quick ratio Immediate liquidity
ratio
Cash ratio
Liquidity ratios
12/31/2019 12/31/2020 12/31/2021

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3. CAPITAL RESOURCES
FINANCIAL AUTONOMY RATIOS
Table No 5
DEBT RATIOS 12/31/2019 12/31/2020 12/31/2021
Debt / Equity 0.31 0.16 0.10
Debt / Assets 0.24 0.13 0.09
Equity/ Debt 4.17 6.42 9.60
The change in the debt/equity ratio at the end of the reporting period is due to the following: the Company’s total
liabilities decreased by 22, 9 % compared to the end of 2020, and equity in creased by 14,8 %.
The change in the debt/assets ratio at the end o f the reporting period is due to the following: the Company’s total
assets in creased by 10, 2 % compared to the end of 2020, while the Company’s total liabilities decreased by 22, 9 %.
The change in the financial autonomy ratio at the end of the reporting period is due to the following: the total
liabilities of the Company decreased by 22,8 % compared to the end of 2020, and the equity has in creased by 14.8 %.
3. KEY INDICATORS
Summary information on the financial performance of ALLTERCO JSCo for the last three financial periods is presented
in the following charts and tables:
0.00
2.00
4.00
6.00
8.00
10.00
12.00
Debt / Equity Debt / Assets Equity/ Debt
Debt ratios
12/31/2019 12/31/2020 12/31/2021

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Table No 6
The calculation of the above indicators includes the revenues from dividends and the positive differences from the sale
of financial assets (realized in the last three reporting periods ), which are ordinary operating revenues for a holding
company.
Table No 7
Thousand BGN
INDICATORS 2019 2020 2021
Net sales revenue 46 342 46 342 59 509
Equity 30 336 56 836 65 572
Non - current liabilities 2 626 2 549 2 087
Current liabilities 6 929 6 308 4 746
Non - current assets 17 679 18 603 12 991
Current assets 22 212 47 090 59 414
Working capital 15 283 40 782 54 668
Cash 10 931 26 050 30 541
Total debt 9 555 8 857 6 833
Interest expense 102 90 78
Inventories 1 285 3 660 7 560
Short - term receivables 5 431 13 948 19 167
Expenditure on ordinary activities 8 138 9 343 14 081
Expenditure on materials 862 131 190
0
5 000
10 000
15 000
20 000
25 000
EBITDA EBIT
2019 2020 2021
Thousand BGN
2019 2020 2021
EBITDA 9 383 16 150 19 149
EBIT 8 564 15 797 18 956

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4. PROFITABILITY INDICATORS
Table No 8
Profitability ratios 2019 2020 2021
Return on Registered capital 0.487 0.747 0.887
ROE 0.242 0.235 0.243
ROA 0.183 0.205 0.220
Return on equity (ROE)
As of the end of the reporting period, the Return on equity ratio increase d to 0, 243 compared to the same period of the
previous financial year. The reason for this is the increase by 18,8 % in the net profit of the company. In 2021 compared
to 2020, the company's eq uity in creased by 14,8 %.
Return on assets (ROA)
The value of ROA ratio as of the end of the reporting period is 0,220 and increases compared to the previous financial
year. For 2020, ALLTERCO JSCo reports an increase of the net profit, whereas the compan y ’ s assets in crease d by 10, 2 %.
Return on registered capital
As of the end of the reporting period, the Return on registered capital is 0,887 and it decreases compared to 2020. In 2021
compared to 2020, the company's net profit increase, whereas the company registered capital is unchanged.
IV. INFORMATION ON ENVIRONMENTAL AND PERSONNEL ISSUES HUMAN RESOURCES
As of the end of the reporting period, the number of employees of the Group i s 102 , and out of them the number of
managerial personnel is 7 .
The relationships with workers and employees are regulated with individual employment contracts.
The Company's management strives to improve the standard of living of its employees , including the employees of all
Group companies . The total remuneration and social security for 2021 amounted to BGN 7 590 thousand (2020: BGN
6 115 thousand).
0
0.2
0.4
0.6
0.8
1
Рентабилност на
регистрирания капитал
Рентабилност на
собствения капитал ( ROE)
Рентабилност на активите
( ROA)
Profitability ratios
2019 2020 2021

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V. ENVIRONMENTAL PROTECTION POLICY
The company does not carry out activities that harm the environment. Never theless, the Company strives to limit
the use of materials produced from non - renewable energy sources and implements a program for energy conservation.
VI. REPORTING OF NON - FINANCIAL INFORMATION
In accordance with the requirements of Directive 2014/95/EU of t he European Parliament on reporting non - financial
information and the provisions of the Accountancy Act, for a number of companies arises an obligation to publish non -
financial information alone or as part of the annual business activity reports.
The oblig ation arises for large public - interest entities which, as at 31 December of the reporting period, exceed the
criterion for an average number of employees in the financial year of 500 persons. Companies of public interest are:
public companies and other is suers of securities; credit institutions; financial institutions; insurers and reinsurers, pension
insurance companies and funds managed by them; investment intermediaries; trading companies that produce, transport
and sell electricity and heat; commercial companies that import, transport, distribute and transit natural gas; commercial
companies providing water, sewer and telecommunications services; Bulgarian State Railways EAD and its subsidiaries.
Large enterprises are defined as those with net sales revenues - BGN 76 million or the carrying amount of the assets -
BGN 38 million.
Given the criteria set out in the Accountancy Act, it can be concluded that Allterco JSCo does not, on a consolidated
basis, incur an obligation to report non - financial information on its own or as part of the report of the Board of Directors.
VII. MAJOR RISKS FOR THE COMPANY
The risks related to the business operation of the Company can be generally divided into systematic (overall) and non -
systematic (pertaining specifical ly to its activity and the field where it operates). The Company is also associated with the
similar risk categories typical for its activity and field where its subsidiaries operate. In addition, the investors in fina ncial
instruments of the Company are e xposed to risks related to investments in securities.
SYSTEMATIC RISKS
Systematic risks are related to the market and the macro environment in which the Company operates, which is why they
cannot be managed and controlled by the company's management team. Systematic risks are the following: political risk,
macroeconomic risk, inflation risk, foreign exchange risk, interest rate risk, tax risk and unemployment risk.
Type of risk Description
POLITICAL RISK Political risk is the likelihood of a change of Government, or of a sudden change in its policy, of
occurrence of internal political turmoil and adverse changes in European and/or national legislation,
as a result of which the environment in which local businesses operate will change negatively, and
investors will incur losses. In November 2021, the country held for the second time early
parliamentary elections for the Ordinary National Assembly, as a result of which for the political
party ruling in last 12 years lost its posit ion in the state governance and a new government is expected
to be formed.
Political risks for Bulgaria internationally are related to the commitments undertaken to implement
serious structural reforms in the country in its capacity as an equal member of the EU, increasing
social stability, limiting inefficient spending, on the one hand, as well as the strong destabilization

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of the countries of The Middle East, the increasing threat of terrorist attacks in Europe, refugee waves
and instability of key count ries in the immediate vicinity of Bulgaria.
Other factors that also affect this risk are the possible legislative changes and in particular those
concerning the economic and investment climate in the country.
The geopolitical situation in the region is fur ther complicated by the development of the Russian -
Ukrainian crisis after Russia recognized the independence of the two regions in eastern Ukraine and
sent troops to Ukraine, while the US and the EU imposed economic sanctions on Russia. Currently
the effec t of this risk on the Company is insignificant as the focus of the business is not directed
towards the Russian and Ukrainian markets and accordingly a minimal portion of the Company's
revenue is generated from sporadic one - off sales mainly to end users.
GENERAL
MACRO -
ECONOMIC RISK
According to the National Statistical Institute, in December 2021 the total business climate indicator
increased by 2.6 percentage points compared to the previous month. An increase in the indicator
was observed in constructi on and retail trade and in the services sector, whereas in the industry sector
there is a decrease.
.
Business climate - total
Source: NSI 1
Compared with the previous projections, the growth outlook for the global economy in the December
2021 Eurosystem staff macroeconomic projections has been revised downwards for 2021, remained
unchanged for 2022 and been revised upwards for 2023. Global real GDP growth (excluding the
euro area) is estimated to increase to 6.0% in 2021, before slowing to 4.5% in 2022, 3.9% in 2023
and 3.7% in 2024. Euro area foreign demand is projected to expand by 8.9% in 2021, 4.0% in 2022,
4.3% in 2023 and 3.9% in 2024. However, foreign demand has been revised downwards for 2021
and 2022 compared with the previous projectio ns 2
INTEREST RATE
RISK
The interest rate risk is related to possible, eventual, adverse changes in the interest rates established
by the financial institutions of the Republic of Bulgaria.
At its meeting in October, 2021, the Board of Directors of the ECB, confirmed its other measures to
support the ECB’s price stability mandate, namely the level of the key ECB interest rates and the
forward guidance on the future path of policy rates. This is crucial for maintaining the appropriate
degree of accomm odation to stabilize inflation at the ECB’s 2% inflation target over the medium
term. 3
Date Percentage
01.11.2021 0.00
01.11.2021 0.00
01.10.2021 0.00
01.09.2021 0.00
1 http://nsi.bg/bg/content/14830/общ - показател - на - бизнес - климата
2 https://www.bnb.bg/bnbweb/groups/public/documents/ecb_publication/publications_ecb_mb_202108_bg.pdf
3 https://www.bnb.bg/bnbweb/groups/public/documents/ecb_publication/publications_ecb_mb_202108_bg.pdf

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01.08.2021 0.00
01.07.2021 0.00
01.06.2021 0.00
01.05.2021 0.00
01.04.2021 0.00
01.03.2021 0.00
01.02.2021 0.00
01.01.2021 0.00
*Source: BNB 4
INFLATION RISK Inflation risk is a general rise in prices in which money depreciates and there exists a probability of
loss to households and firms.
The consumer price index (CPI) is an official measure of inflation in the Republic of Bulgaria. It
estimates the total relative change in the prices of goods and services used by households for personal
(non - production) consumption and the index is calcula ted by applying the structure of the final cash
consumer expenditure of Bulgarian households.
According to the NSI the consumer price index for December 2021 compared to November 2021 is
100.9%, i.e., monthly inflation is 0.9%. The annual inflation for De cember 2021 compared to
December 2020 is 7.8%. The average annual Inflation for the period January - December 2021
compared to the period January – December 2020 is 3.3.%. 5
*Source: NSI
The harmonized index of consumer prices (HICP) is a comparable measure of inflation in EU
countries. It is one of the criteria for price stability and for Bulgaria’s accession to the euro area. The
HICP, like the CPI, measures the overall rela tive change in the price level of goods and services.
According to the NSI the harmonized index of consumer price index for December 2021 compared
to November 2021 is 100.8%, i.e., monthly inflation is 0.8%. The annual inflation for December
2021 compared to December 2020 is 6.6%. The average annual Inflation for the period January -
December 2021 compared to the period January – December 2020 is 2.8%. In November 2021 the
inflation keeps increasing to 4.9 %. During most of 2022 it will stay above 2% where as in the near
future the inflation is expected to stay high, but to decrease in the course of the present year. 6
The December 2021 Eurosystem staff macroeconomic projections foresee annual inflation at 2.6%
in 2021, 3.2% in 2022, 1.8% in 2023 and 1.8% i n 2024 – significantly higher than in the previous
projections in September. Inflation excluding food and energy is projected to average 1.4% in 2021,
1.9% in 2022, 1.7% in 2023 and 1.8% in 2024, also higher than in the September projections. 7
CURRENCY RISK Exposure to currency risk is the dependence and effects of changes in exchange rates. Systemic
4 https://www.bnb.bg/Statistics/StBIRAndIndices/StBIBaseInterestRate/index.htm
5 https://www.nsi.bg/sites/default/files/files/pressrelea ses/Inflation2021 - 09_8M1FIED.pdf
6 https://www .nsi.bg/sites/default/files/files/pressreleases/Inflation2021 - 09_8M1FIED.pdf
7 https://www.bnb.bg/bnbweb/groups/public/documents/ecb_publicatio n/publications_ecb_mb_202108_bg.pdf
The respective month of the previous year The previous month

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currency risk is the probability of a possible change in the currency regime of the country (currency
board), which would lead either to BGN devalu ation or to BGN appreciation compared to foreign
currencies.
Currency risk will have an impact on companies with market shares, the payments of which are made
in a currency other than BGN and EUR. Since, according to the current legislation in the country the
Bulgarian lev is fixed to the euro in the ratio EUR 1 = BGN 1.95583, and the Bulgarian National
Bank is obliged to maintain a level of Bulgarian levs in circulation equal to the bank’s foreign
exchange reserves, the risk of devaluation of the BGN compa red to the European currency is minimal
and consists in the eventual early abolition of the currency board in the country. At this stage, this
seems unlikely, as the currency board is expected to be abolished upon the adoption of the EUR in
Bulgaria as an official unit of payment.
Theoretically, currency risk could increase when Bulgaria joins the second stage of the European
Exchange Rate Mechanism (ERM II). This is a regime in which the country must maintain the
exchange rate compared to the EUR within +/ - 15% on the background of the central parity. In
practice, all countries currently in this mechanism (Denmark, Estonia, Cyprus, Lithuania, Latvia,
Malta) are witnessing fluctuations that are significantly less than the allowed ones of ± 15%.
On July 10, 2 020, Bulgaria joined the ERM II exchange rate mechanism, known as the ‘euro area’s
waiting room’. The central rate of the Bulgarian lev is fixed at EUR 1 = BGN 1.95583. Around this
central exchange rate of the BGN, the standard range of plus or minus 15 pe rcent will be maintained.
Bulgaria joins the exchange rate mechanism with its existing currency board regime, as a unilateral
commitment and without additional requirements to the ECB. 8 At the same time, our country must
enter into close cooperation with the unified banking supervision. The fixed exchange rate of the
BGN to the EUR does not eliminate for the Bulgarian currency the risk of unfavorable movements
of the euro exchange rate against other major currencies (US dollar, British pound, Swiss franc) on
the international financial markets, but at present the company does not consider that such a risk
would be material to its business. The company may be affected by currency risk depending on the
type of cash flow currency and the type of currency of th e company’s potential loans.
The Allterco JSCo Group companies operate in Bulgaria as well as in EU countries and first
countries, mainly in the USA and the Asia - Pacific region. At present, the main revenues from the
Group’s IoT business are in BGN or EUR, and the costs of delivery of goods in this segment are
mainly in US dollars and are largely tied to the Chinese yuan, which is why the appreciation of the
US dollar or Chinese yuan would have an adverse effect on the business performance. In terms of
US d ollar exposure, the Group companies are expected to have significant US dollar sales revenue
in the US and other non - EU markets in the future, which to some extent balances the Group’s net
exposure to this major currency.
To limit the effects of the curren cy risk, the companies of the Group have introduced a system for
planning the deliveries from countries inside and outside the EU, as well as procedures for ongoing
monitoring of the movements in the exchange rates of the foreign currencies and control ove r the
forthcoming payments. Currently, the Group companies do not use derivative instruments for
hedging the currency risk but, if necessary, the management is ready to enter into such transactions.
Credit risk of the
state Credit risk is the probability of deterioration of Bulgaria’s international credit ratings, caused by the
government’s inability to repay its liabilities regularly. Low credit ratings of the country can lead to
higher interest rates, more difficult financing conditions, both for the state and for individual
economic entities, including the Issuer. Credit ratings are prepared by specialized credit rating
agencies and serve to determine and measure a country’s credit risk. Bulgaria’s credit rating is
presented in the following table:
Table 1: Credit risk of Bulgaria
Credit agency Date of last change Long - term rating Prospects
Standard & Poor‘s 30.11.2021 9 BBB Stable
8 https://www.ecb.europa.eu/press/pr/date/2020/html/ecb.pr200710~4aa5e3565a.en.html
9 https://www.minfin.bg/bg/news/11577

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Fitch 22.01.2022 1 10 BBB Stable
Source: Ministry of Finance
The international credit rating agency S&P Global Ratings affirmed its long - term and short - term
foreign and local currency sovereign credit ratings on Bulgaria at “BBB/A - 2”. The outlook remains
stable.
According to the credit rating agency, the economic effects of the pandemic have been manageable,
despite a significant health impact. Domestic demand, particularly private consumption, has
recovered strongly and the increased absorption of EU funds will lift the medium - term growth
outlook. The funds under the previous and current EU Multiannual Finan cial Framework (EU MFF)
and the additional funds under the new Next Generation EU (NGEU) instrument available to the
country are estimated at about 40% of the expected 2021 GDP.
S&P forecasts the fiscal deficit to remain significant in 2021, too, as a resu lt of the support measures
during the pandemic. Although some measures are projected to continue into 2022, the credit rating
agency expects the deficits to start narrowing from 2022 and notes Bulgaria’s established record of
fiscal prudence under several governments. Despite the fiscal loosening and the increased public
leverage, Bulgaria’s net government debt levels remain low at around 20% of GDP, whereas
sovereign funding costs have reduced to record - lows.
According to S&P, in line with global trends, i nflation in Bulgaria has increased in 2021, due to a
combination of rising food and energy prices, as well as strengthening domestic demand weighing
on core inflation. Price increases should reduce in the second half of 2022.
External risks are manageable after several years of external net deleveraging, thanks to recurring
current and capital account surpluses, which the credit rating agency expects to continue.
The credit rating agency also considers positive that the lev was included in the ERM II and Bu lgaria
joined the Banking Union in 2020. The ratings are constrained by the country's GDP per capita,
which is moderate by global standards and the remaining structural and institutional impediments.
The stable outlook indicates the expectation that Bulgar ia's economic recovery will progress over
the next two years, backed by further absorption of additional EU funds. Although several fiscal
support measures will extend into 2022, the credit rating agency expects fiscal balances to narrow
over the next two years, which will keep public debt low. The stable rating outlook also reflects the
expectations that the economy will not incur any external or financial sector imbalances.
The credit rating agency could raise the ratings if Bulgaria's economic recovery c oincides with
quicker fiscal consolidation or stronger external performance than it currently projects. In the long
term, the ratings on Bulgaria could be raised in the course of its accession to the eurozone. The
ratings could be lowered if the economic r ecovery is delayed, for example, because the pandemic's
direct effects prove more long - lasting than currently expected. This would likely result in protracted
fiscal consolidation and continuously rising net public debt over the next few years. Although
un likely over the medium term, S&P could take negative rating actions in case of emergence of
imbalances in Bulgaria's financial sector. 11
The international credit rating agency Fitch Ratings has affirmed Bulgaria’s long - term foreign and
local currency Issu er Default Ratings (IDR) at “BBB” with a Positive Outlook.
The Positive Outlook reflects the dissipation of macroeconomic risks stemming from the Covid - 19
pandemic and a more resilient economy, as well as continued progress towards the euro adoption.
Accor ding to the credit rating agency, short - term downside risks tied to the pandemic and electoral
uncertainty are more than offset by prospects of substantial funding from the EU and a commitment
to macro and fiscal stability.
Bulgaria's ratings are supported by its strong external and fiscal position, the credible policy
framework, underpinned by EU membership and a long - standing currency - board arrangement. The
ratings are constrained by the potential growth due to unfavorable demographics, which cou ld weigh
on government finances over the long term. Governance indicators and income levels are slightly
above the median for peers.
Fitch expects Bulgaria’s economic growth to accelerate to 4.7% in 2021, compared to the estimate
for 3% from February. The upward revision reflects better - than - expected 1Q21 GDP and the
expected strengthening of domestic demand and exports in the second half of the year. Bulgaria ́s
low vaccination rate compared to the EU average raises some downside pandemic - related risks;
how ever, according to the agency, authorities are unlikely to put in place more severe containment

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measures that would significantly affect economic activity in the country.
Investment is expected to be a key driver of growth over the medium - term, as Bulgaria will be one
of the main beneficiaries of EU transfers in the coming years. The analysts of Fitch believe that the
significant amount of funds under the Recovery and Resilience Facility (RRF) would support the
growth of the economy which is estimated at 3. 9% in 2022 - 23.
The credit rating agency projects the fiscal deficit (on accrual basis) at 5% of GDP in 2021, versus
5.5% for the BBB median, reflecting mostly the Covid - 19 related expenditure. It expects the deficit
to narrow to 2% in 2023, keeping public debt/GDP at below 30% (versus 57% for BBB peers). Fitch
considers the plan for euro adoption in 2024 realistic. The country's banking sector is estimated as
liquid and well capitalized.
The main factors that could lead to positive rating action/upgr ade are: progress toward euro area
accession and improvement in the economy’s growth potential that leads to faster convergence with
income levels of higher rated peers. The factors that could lead to negative rating action/downgrade
are: adverse policy de velopments that reduce confidence in economic recovery; a prolonged rise in
public debt; the materialization of contingent liabilities on the sovereign's balance sheet or weaker
growth prospects.
Unemployment risk As a major factor influencing consumers’ purchasing power, rising unemployment would reduce
demand for IoT products. On the other hand, the demand for staff by the business remains extremely
active, so that such a risk appears to be negligible within the next year.
According to the statistics pub lished by Eurostat 13.984 million men and women in the EU, of whom
11.829 million in the euro area, were unemployed in November 2021. Compared with October 2021,
the number of persons unemployed decreased by 247 000 in the EU and by 222 000 in the euro are a.
Compared with November 2020, unemployment decreased by 1.659 million in the EU and by 1.411
million in the euro area. 12 The level of registered unemployment in the country continued to be low
in December – 4.8%, as shows the administrative statistics of the Employment Agency for the month.
The decline on an annual basis is by 1.9 percentage points. The registered persons unemployed in
the last month of 2021 were 157 283, which is 964 less than in November and 63 009 or 28.6% less
than a year earlier. In December, 21 505 new unemployed persons registered with the labor offices,
which is 3 145 people less than in the previous month, and compared to December 2020 there was a
decrease of 11 102 people. 13
Risk associated with
the legal system Although Bulgaria has introduced a number of significant legislative changes since joining the EU
and most of the Bulgarian legislation has been harmonized with EU legislation, the legal system in
the country is still in the process of reform. Judicial and administ rative practices remain problematic
and it is difficult to effectively resolve property disputes, breaches of laws and contracts and other.
Deficiencies in the legal infrastructure can result in uncertainties arising from the implementation of
corporate ac tions, the implementation of supervision and other issues.
TAX RISK It is essential for the financial performance of the companies to maintain the current tax regime.
There is no guarantee that the tax legislation, which is directly relevant to the core business of the
Company, will not be changed in a direction that would lead to significant unforeseen expenses and,
accordingly, would adversely affect its profit. The taxation system in Bulgaria is still developing, as
a result of which a contradicto ry tax practice may arise.
10 https://www.minfin.bg/bg/news/11631
11 https://www.minfin.bg/bg/news/11577
12 https://ec.europa.eu/eurostat/statistics - explained/index.php?title=Unemployment_statistics
13 https://www.az.government.bg/bg/news/view/2021 - g - prikluchi - s - rekordno - nisko - nivo - na - bezrabotica - 3772/

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NON - SYSTEMATIC RISKS
Risks related to the industry in which the Group operates
Such risks are: risk of shortage of key personnel, risk of strong competition, risk related to personal data security and
hacker attacks, risk of technology change.
Risk of shortage of key personnel
One of the biggest challenges for technology companies, such as the companies of the Group, as well as given the specific
scope of their business in the field of telecommunications and engineering and s oftware development, is the shortage of
skilled personnel. Insufficient availability of suitable staff in the subsidiaries could adversely affect the future
development of the Group due to delays in the development of new products/services and the maintena nce of existing
ones. On the other hand, the high competition in this sector raises the cost of labor. Thus, the financial position and marke t
share of the Group companies could suffer.
Risk of strong competition
After the sale of most of the telecommunica tion business of the group, the Group companies operate mainly in the segment
of the Internet of Things (IoT). This segment is one of the most modern and promising sectors of the industry, which
attracts the interest of many technology giants and start - up companies. The loss or inability to gain market share and the
fall in final product prices due to increased competition may have a negative effect on revenue, profit and profit margins.
Maintaining a competitive position requires investment in the creation of devices with new utilities, improvement of
existing solutions and expansion of market share and it cannot be taken for granted that new developments will be
established among the competing ones on the market.
Risk related to personal data security and hacker attacks
The technology industry is characterized by digital transmission of information that could be strictly confidential,
containing personal data of users of products, financial information of companies, information about new produc ts and
other. The protection of such information is a critical factor for the normal operation of companies in the industry,
including of the Group. The sales of the devices and the use by the users of the accompanying mobile applications and
cloud service s provided by the Group are related to the exchange and storage of personal data. Potential breaches in
information security can lead to: i) Loss of customers and/or partners and their migration to competing companies; (ii)
Imposing sanctions and lawsuits related to breaches of applicable data protection and privacy laws; iii) Lost or delayed
orders and sales; iv) Adverse effects on reputation, business, financial position, profits and cash flows.
Risk of regulatory and specific technical requirements
The s upply of IoT devices is related to regulation regarding the certification of products for sale in the respective country.
In the European Union, products are required to bear the ‘CE’ marking, which indicates that the product has been
evaluated and meets the requirements of safety, health and environmental protection. In the US, the equivalent is ‘UL’
certification. For certification purposes, accredited laboratories are assigned compliance tests, which involve significant
costs. In addition, specifi cs in the requirements of local regulators and contractors (especially mobile operators) may
require additional tests and certification to be performed, which increases the cost of entering a particular market or
particular distribution channel.
Sales of t he Group companies’ products cover an increasing number of markets, which often have local regulation

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regarding the certification of similar products in the respective country. Meeting the requirements of local regulation is
related to time and resources a nd may delay the Company in entering new markets or require additional costs in order to
meet different standards.
The change in regulatory requirements for devices may involve additional costs for making them compliant with the new
requirements, including costs for withdrawing products from the market to making them compliant with these
requirements. The Group companies and their local partners regularly monitor planned changes in the legislation and take
timely measures to ensure the compliance of product s with them.
Eventual changes in the regulations in the telecommunications sector, could have some impact on the operation of the
Group as mobile operators are one of the main sales channels for existing MyKi series products. Big part of the devices
develo ped and sold by the companies in the IoT Group use Internet - based technology and can work with the services of
any Internet provider. To that effect, the Group is now less dependent on regulations in the field of telecommunications,
insofar as the companie s in its structure are not providers of telecommunication services and mobile operators are only
one of the channels for trade and distribution of IoT devices.
Risk of technology change
The Issuer and its subsidiaries operate in an extremely dynamic segmen t, in which technologies have a significant impact
and are a source of competitive advantage. To that effect, there is a risk of delayed adaptation to new technologies due to
lack of knowledge, experience or sufficient funding, which may have a negative im pact on the Issuer. The slow adaptation
to the new realities may lead to a loss of competitive positions and market shares, which in turn will lead to a deterioratio n
of the Group’s performance.
Risks related to the Group’s business
Such risks are: operati onal risk, risk related to business partners, risks arising from new projects and liquidity risk.
Operational risk
Operational risk can be defined as the risk of loss as a result of inadequate or non - functioning internal management
procedures. Such risks m ay be caused by the following circumstances:
• Adoption of wrong operational decisions by the management staff related to the management of current projects;
• Insufficient amount of skilled personnel needed for the development and implementation of new projec ts;
• Leaving key employees and inability to replace them with new ones;
• Risk of excessive increase in management and administration costs, leading to a decrease in the overall profitability
of the Issuer;
• Technical damages leading to prolonged interruption of the provided services may lead to termination of contracts
with clients.
The effects of such circumstances would be a decrease in the Issuer’s revenues and deterioration of its business
performance.
Risk associated with business partners
Production acti vities in the IoT segment is outsourced, mainly to China, concentrated in several manufacturers. Potential

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risks associated with key subcontractors are related to the accurate and timely execution of deliveries or termination of
business relationships. Alt hough management believes that there is a wide range of alternative suppliers, the possible
transfer of production to new partners and diversification of subcontractors may lead to delivery delays and additional
costs, which may affect the ability of the G roup companies to perform agreed orders from customers and adversely affect
the Group’s reputation and financial performance.
Risks related to new projects
The main business activity of Allterco JSCo is related to investments in subsidiaries. There is a ri sk that some of the
subsidiaries will not be able to meet their goals, which will lead to lower or negative return on investment.
The development of new products and services by the subsidiaries of Allterco JSCo is related to the investment in human
resour ces, software, hardware, materials, goods and services. Should new products and services fail to be marketed, such
investments would be unjustified. This in turn would have a negative impact on the costs and assets of the Company, as
well as on the perform ance of its business activities. In order to manage the risk arising from new projects, the Group
companies perform a market analysis, prepare a financial analysis containing different scenarios, and in some cases
discuss with potential customers the conce pt of the new service/product.
Liquidity risk
The expression of the liquidity risk in relation to the Group is associated with the possibility of lack of timely and/or
sufficient available funds to meet all current liabilities. This risk may appear both in case of significant delay of the
payments by the debtors of the Company, as well as in case of insufficiently effective management of the cash flows from
the operation of the Company.
Some of the Group companies use bank financing in the form of an investment loan, overdraft or revolving credit line,
which can be used in case of liquidity problems.
The company pursues a conservative liquidity management policy, through which it constantly maintains an optimal
liquidity cash reserve and good ability t o finance its business activities. In order to control the risk, the Company monitors
the timely payment of incurred liabilities. The company monitors and controls the actual and projected cash flows for
periods ahead and maintains a balance between the ma turity limits of the assets and liabilities.
VIII. IMPORTANT EVENTS AFTER THE DATE OF FINANCIAL STATEMENTS
The events occurring after the reporting date are disclosed in note 1 0 of the notes to the 2021 consolidated financial
statements.
IX. CURRENT TRENDS AND POS SIBLE FUTURE DEVELOPMENT OF THE COMPANY
As of the end of the reporting period Allterco JSCo reported on consolidated basis operating revenue in the amount of BGN
61 007 thousand which is an increase of 28.8% compared to the operating revenue on consolidate d basis for 2020, which
amounted to BGN 47 355 thousand.

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Table No 9
REVENUE 2019 change 2020 change 2021
Thousand
BGN %
Thousand
BGN %
Thousand
BGN
Sale of goods and production 21 039 85.9% 39 117 50.4% 58 831
Revenue from services and rents 12 279 - 41.2% 7 225 - 90.6% 678
Other operating revenue 182 456.6% 1 013 47.9% 1 498
Total operating revenue 33 500 41.4% 47 355 28.8% 61 007
Gain from operation s with financial assets 8475 - 59.3% 3 446 - 92.7% 250
Total financial income 8475 - 59 .3 % 3 446 - 9 2.7 % 250
ALLTERCO JSCo does not carry out direct production activities. The production activity is carried out by the
subsidiaries.
In 2022, Allterco JSCo will continue to operate in the following main areas:
Table 10
Company name Operational ar ea for 2021
Allterco JSCo – mother company 1. Observation, control and decision - making on important issues
affecting subsidiaries as sole proprietor or majority owner through:
• applying the principles of good corporate governance;
• organizing conditions for efficient and transparent work;
• improving the quality of the offered services and products.
2. Asset transactions of the company and its subsidiaries
3. Establishment of the management structure
4. Financing of investment activity and operating capital of subsidiaries
5. Financial and accounting policy and reporting
Allterco Trading EOOD 1. Manufacturing of child watches and trackers;
2. B2B trading and distribution of IoT devices, developed or
manufactured by Allterco Robotics EOOD
Allterco Robotics EOOD Development and sale of IoT devices.
Research and development activities in the area of IoT devices.
Allterco Properties EOOD Provisi on of offices and cars for rent.
Allterco Europe GmbH, Germany Trade and distribution of IoT products in Europe
Allterco Robotics USA Inc., USA Sale and distribution of IoT products in North and South America
X. ACTIVITIES IN THE FIELD OF RESEARCH AND DEVELOPMENT
The company did not carry out any activities in the field of research and development and does not plan any in the near
future. One of the subsidiaries of Allterco JSCo carried out such activity in 2021. This is Allterco Robotics EOOD.
XI. INFORMA TION ABOUT THE ACQUISITION OF OWN SHARES REQUIRED IN ACCORDANCE
WITH ART. 187e (д) OF THE COMMERCIAL ACT
1. Number and nominal value of own shares acquired and transferred during the year, the part of the capital they
represent, as well as the price for th e acquisition or the transfer
In 2021, ALLTERCO JSCo did not acquire or transfer its own shares.

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In 2021, two of the subsidiaries of Allterco JSCo, namely Allterco Robotics EOOD and Allterco Trading EOOD have
disposed of shares (ISIN BG1100003166) from the capital of the public listed parent company, which according to Art.
187f, item 2 of the Commerce Act is equivalent to acquisition of own shares.
In December 2020 Allterco Robotics EOOD and Allterco Trading EOOD acquired a total of 2 0 000 shares of Allterco
JSCo, representing 0.11% of the capital of the public company, in order to be provided to employees of the two
subsidiaries under conditions additionally determined by the management. The shares were acquired on a regulated
market - Bulgarian Stock Exchange AD on 02.12.2020 at market price. Allterco Robotics EOOD has purchase of 13 000
shares and Allterco Trading EOOD - 7 000 shares. The shares were acquired on a regulated market at price of BGN 6.90.
In 2021, within the statutory p eriod of one year from the date of acquisition, the companies have transferred the said
number of shares pursuant to a resolution of the Board of Directors to grant shares to employees of these companies. The
transfer transactions are as follows:
Allterco Robotics EOOD has transferred:
• in January 2021 – 3883 shares at average price of BGN 6.925 per share outside regulated market;
• in December 2021 – 9117 shares at average price BGN 24.40 per share outside regulated market;
Allterco Trading EOOD has transferr ed:
• in January 2021 - 2099 shares at average price of BGN 6.916 per share outside regulated market;
• in December 2021 – 4901 shares at average price BGN 24.40 per share outside regulated market;
2. Number and nominal value of own shares and the part of the capital they represent
As of the end of the reporting period, the Company does not hold own shares.
As of the end of the reporting period neither of the Company’s subsidiaries, including Allterco Robotics EOOD and
Allterco Trading EOOD holds shares of the of the public listed parent company, equal to own shares.
XII. INFORMATION REQUIRED UNDER ART. 247 OF THE COMMERCIAL ACT
1. Total remuneration received during the year by the members of the Board of Directors.
The members of the Board of Directors of Allterco JSCo received the following remunerations in 2021.
Table No 1 1
Full name Position Gross/thousand
BGN
Dimitar Stoyanov Dimitrov Executive Director 48
Svetlin Iliev Todorov Chairperson of the Board of Directors 48
Nikolay Angelov Martinov Independent member 34
As of the end of the reporting period all remunerations are paid to the members of the Board of Directors.
No further remunerations - money and non - cash compensation are paid to the members of the Board of Directors.
There are no spe cial rights or any privileges for the members of the Board of Directors stipulated in the Articles of
Association of the Company.
During the reporting year, some of the members of the Board of Directors received remuneration from the subsidiaries
for perf orming other functions .

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2. Shares and bonds of the Company acquired, owned and transferred by the members of the Board of Directors
during the year:
As of the end of the reporting period, the shares held by members of the Board of Directors of ALLTERCO JSCo are:
Table No. 1 2
Name PERCENTAGE OF THE CAPITAL
Dimitar Stoyanov Dimitrov 32.48 %
Svetlin Iliev Todorov 32.48 %
Nikolay Angelov Martinov* 0 %
* Nikolay Martinov has no direct interest in the capital of the Issuer. The companies Unicom Consult EOOD, in which he is the sole
owner of the capital and manager, Impetus Capital OOD and Impetus Partners OOD, in which he is a partner resp ectively with 50%
and 43,75 % of the capital and manager, as well as Imventure I KDA and Imvencher II KDA, in which he is a representative of the
legal entity - "IMPETUS CAPITAL" OOD, have respectively: "Unicom Consult “EOOD – 84,750 shares (0.47%), Impetu s Capital
OOD 27,000. shares and 162,000 voting rights (0.9%), Impetus Partners OOD 405,000 shares (2.25%) ImVenture I KDA 123,288
shares (0.68%), Imventure II KDA - 68,493. shares (0.38%) in the capital of Allterco JSCo and a total 708,531 number of share s and
843,531 voting rights (4.686%) of the voting rights in its General Meeting.
3. Rights of the members of the Board of Directors to acquire shares and bonds of the Company
The members of the Board of Directors of the company may freely acquire shares from the capital of the company on a
regulated securities market in compliance with the provisions of the Law on the enforcement of measures against market
abuse of financial instruments, REGULATION (EU) No 596/2014 OF THE EUROPEAN PARLIAMENT AND OF THE
CO UNCIL of 16 April 2014 on market abuse (market abuse regulation) and the Public Offering of Securities Act.
On the basis of the provision of Art. 19 of the Market Abuse Regulation the members of the Board of Directors of the
company, other persons holding executive functions in the Issuer, and the persons closely related to them, shall notify in
writing the Adventure Company and FSC of any transactions concluded on their behalf with shares issued by Allterco
JSCo within 3 business days after the transaction . The obligation to notify does not apply when the total amount of
transactions concluded by a person performing management functions in the issuer and in the persons closely related to
him does not exceed EUR 5 000 within one calendar year.
4. Participation of the members of the Board of Directors in companies as unlimited partners, holding more than
25 percent of the capital, as well as their participation in the management of other companies or cooperatives as
procurators, managers or board me mbers as of the end of the reporting period:
Table No 1 3
Dimitar Dimitrov as of 31.12.2021
Participation in the governing and
supervisory bodies of other companies,
their participation as procurators and
unlimited partners
Participation in the capital of other
companies
Companies in which the person
exercises control
DVR Review EOOD (Solely - owned LLC)
entered in the Commercial Register at the
Registry Agency under Unified
Identification Code (UIC): 130554234,
having its registered seat and headquarters
address in the town of Samokov, 1, Zhitna
Charshiya Street, Floor 1
DVR Review EOOD (Solely - owned
LLC) entered in the Commercial
Register at the Registry Agency under
Unified Identification Code (UIC):
130554234, having its registered seat
and headquarters address in the town
of Samokov, 1, Zhitna Charshiya
DVR Review EOOD (Solely - owned
LLC) entered in the Commercial
Register at the Registry Agency under
Unified Identification Code (UIC):
130554234, having its registered seat an d
headquarters address in the town of
Samokov, 1, Zhitna Charshiya Street,

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Street, Floor 1 Floor 1 – direct;
Auto Lex Consult EOOD (Solely - owned
LLC) entered in the Commercial Register
at the Registry Agency under Unified
Identification Code (UIC): 201113818,
with registered office in the city of Sofia,
Vitosha municipal district, 5A, Nikola
Petkov Blvd., Floor 4;
Auto Lex Consult EOOD (Solely -
owned LLC), e ntered in the
Commercial Register at the Registry
Agency under Unified Identification
Code 201113818, with reg istered
office in the city of Sofia, Vitosha
District, 5A, Nikola Petkov Blvd.,
Floor 4;
Auto Lex Consult EOOD (Solely -
owned LLC) entered in the Commercial
Register at the Registry Agency under
Unified Identification Code (UIC):
201113818, with registered office in the
city of Sofia, Vitosha municipal district,
5A, Nikola Petkov Blvd., Floor 4 –
direct;
Allterco Pte. Ltd, a company incorporated
under the laws of Singapore with seat and
management address: 422 Orchard Road,
#03 - 01 Claymore Connect, Singapore
238879 (as of the date of this report, this
circumstance is no longer relevant );
Teracomm OOD (Ltd. ), Unified
Identification Code (UIC):
131267949, having its registered seat
and headquarters address in the city of
Sofia 1782, Mladost District, 113A,
Tsarigradsko Shose Blvd.,
Allterco Robotics EOOD (Solely - owned
LLC) , Unified Identification Code
(UIC): 202320104, having its registered
seat and headquarters address in the city
of Sofia, 103, Cherni vrah Blvd. –
indirect through ALLTERCO JSCo
Allterco Robotics US (previous company
name Global Teracomm Ltd.), USA, with
seat and management address: 5851
W.Charleston Blvd. Las Vegas, NV
89146, USA
Web Engine OOD (Ltd.), Unified
Identification Code (UIC):
200303120, having its registered seat
and headquarters address in the city of
Sofia, Sofia 1619, Vitosha District,
5A, Nikola Petkov Blvd.:
Allterco Europe GmbH, registration
number HRB 271205, registered office:
Lothstr. 5, 80335 München, Germany - –
indirect through ALLTERCO JSCo
Allterco Trading EOOD (Solely - owned
LLC) (former name Allterco Finance
OOD /Ltd./), Unified Identification Code
(UIC): 203348672, having its registered
seat and headquarters address in the city
of Sofia, 103, Cherni vrah Blvd. –
indirect through ALLTERCO JSCo;
Allterco Properties EOOD (Solely -
owned LLC) , Unified Identification
Code (UIC): 204639442, having its
registered seat and headquarters address
in the city of Sofia, 103, Cherni V rah
Blvd. – indirect through ALLTERCO
JSCo t ;
Allterco Co Ltd, a company incorporated
under the laws of Thailand with seat and
management address: 19 th Floor,
Ayothaya Tower, Soi Ratchada 18,
Ratchadapisek Road, Huaykwang,
Bangkok 10310, Thailand – indirect
through ALLTERCO JSCo (as of
31.12.2021 this circumstance is no
longer relevant );
Allterco Pte Ltd, a company incorporated
under the laws of Singapore with seat and
management address: 422 Ochard Road,
#03 - 01 Claymore Connect, Singapore
238879 – direct; ( th is circumstance has
ceased to exist after the end of the
reporting period )

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Allterco SDN Ltd., Malaysia, having its
registered seat and headquarters address
in A - 3 - 35B Ioi Boulevard, Jalan Kenari
7, Bandar Puchong Jaya, 47170
PUCHONG, SELANGOR – indirect
through ALLTERCO JSCo;
Allterco Asia Ltd. registration number
91440300MA5GMK2T5B, registered
office number 716, Building A, XingHe
Shiji, Cai Tian road 3069, Gangxia,
Futian, Shenzhen, China – indirect
through Allterco JSCo
Svetlin Todorov as of 31.12.2021
Participation in the governing and
supervisory bodies of other companies,
their participation as procurators and
unlimited partners
Participation in the capital of other
companies
Companies in which the person
exercises control
Teracomm OOD (Ltd.), Unified
Identification Code (UIC): 131267949
having its registered seat and headquarters
address in city of Sofia, 113A,
Tsarigradsko Shose Blvd.,
FF Film Haus OOD (Ltd.), Unified
Identification Code (UIC):
130627604, having its registered seat
and headquarters address in the city of
Sofia, 60, Osogo vo Street – direct;
Allterco Robotics EOOD (Solely - owned
LLC) , Unified Identification Code
(UIC): 202320104, having its registered
seat and headquarters address in the city
of Sofia, 103, Cherni vrah Blvd. –
indirect through Allterco JSCo;
FF Film Haus OOD (Ltd.), UIC
130627604, having its registered seat and
headquarters address in the city of Sofia,
60, Osogovo Street
Teracomm OOD (Ltd.), Unified
Identification Code (UIC): 131267949
having its registered seat and
headquarters address in the Sofia,
113A, Tsarigradsko Shose Blvd. –
20%
Allterco Europe GmbH, registration
number HRB 271205, registered office:
Lothstr. 5, 80335 München, Germany - –
indirect through ALLTERCO JSCo
Allterco Robotics US (previous company
name Global Teracomm Ltd.), USA,
having its registered seat and headquarters
address in 5851 W. Charleston Blvd, Las
Vegas, NV 89146, USA
Web Engine OOD (Ltd.), Unified
Identification Code (UIC):
200303120, having its registered seat
and headquarters address in the city of
Sofia, 5A, Nikola Petkov Blvd. – 20%
Allterco Properties EOOD (Solely -
owned LLC) , Unified Identification
Code (UIC): 204639442, having its
registered seat and headquarters address
in the city of Sofia, 103, Cherni Vrah
Blvd. – indirect through Allterco JSCo;
All terco Trading EOOD (Solely - owned
LLC) (Allterco Finance OOD /Ltd./),
Unified Identification Code (UIC):
203348672, having its registered seat and
headquarters address in the city of Sofia,
103, Cherni V rah Blvd. – indirect
through Allterco JSCo;
Allterco Co Ltd, a company incorporated
under the laws of Thailand with seat and
management address: 19 th Floor,
Ayothaya Tower, Soi Ratchada 18,
Ratchadapisek Road, Huaykwang,
Bangkok 10310, Thailand – indirect
through Allterco JSC (as of 31.12.2021
this circumstance is no longer relevant );
Allterco Pte Ltd, a company
incorporated under the laws of Singapore
with seat and management address: 422
Ochard Road, #03 - 01 Claymore
Connect, Singapore 238879 – indirect
through Allterco JSCo ( that
circumstance has ceased to exist after the

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end of the reporting period );
Allterco SDN Bhd., Malaysia, having its
registered seat and headquarters address
in A - 3 - 35B IOI BOULEVARD, JALAN
KENARI 7, BANDAR PUCHONG
JAYA, 47170 PUCHONG, SELANGOR
- indirect through Allterco JSCo ( th is
circumstance has ceased to exist after the
end of the reporting period ) ;
Allterco Robotics US (previous company
name Global Teracomm Ltd._, USA,
having its registered seat and
headquarters address in 5851
W.Charleston Blvd. Las Vegas, NV
89146, USA - direct;
FF Film Haus OOD (Ltd.), Unified
Identification Code (UIC): 130627604,
having its registered seat and
headquarters address in the city of Sofia,
60, Osogovo Street - direct;
Allterco Asia Ltd. registration number
91440300MA5GMK2T5B, registered
office number 716, Building A, XingHe
Shiji, Cai Tian road 3069, Gangxia,
Futian, Shenzhen, China – indirect
through Allterco JSCo
Nikolay Martinov - as of 31.12.2021
Participation in the governing and
supervisory bodies of other
companies, their participation as
procurators and unlimited partners
Participation in the capital of other
companies
Companies in which the person
exercises control
Unicom Consult EOOD (Solely - owned
LLC) , Unified Identification Code (UIC):
121082655, having its registered seat and
headquarters address in the city of Sofia
1619, Vitosha municipal district, 271,
Tsar Boris III Blvd., Floor 5, Apt. 9;
Unicom Consult EOOD (Solely - owned
LLC) , Unified Identification Code
(UIC): 121082655, having its
registered seat and headquarters
address in the city of Sofia 1619,
Vitosha municipal district, 271, Tsar
Boris III Blvd., Floor 5, Apt. 9 - direct;
Allterco Robotics EOOD (Solely - owned
LLC) , Unified Identification Code
(UIC): 202320104, having its registered
seat and headqu arters address in the city
of Sofia, 103, Cherni Vrah Blvd. -
indirect through ALLTERCO JSCo;
Online Media OOD (Ltd.), Unified
Identification Code (UIC):117004285,
having its registered seat and
headquarters address in the town of Ruse
7000, 6a, PRIDUNAVS KI Blvd.,
Entrance B (2), Floor 1, Apt. 1;
Online Media OOD (Ltd.), Unified
Identification Code (UIC): 117004285,
having its registered seat and
headquarters address in the town of
Ruse 7000, 6a, Pridunavski Blvd.,
Entrance B (2), floor 1, apt. 1 - direct
and indirect through Unicom Consult
EOOD (solely - owned LLC), Unified
Identification Code (UIC): 121082655
Allterco Properties EOOD (Solely -
owned LLC) , Unified Identification
Code (UIC): 204639442, having its
registered seat and headquarters address
in the city of Sofia, 103, Cherni Vrah
Blvd. - indirect through ALLTERCO
JSCo;

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Inbro OOD (Ltd.), Unified Identification
Code (UIC): 121003506, having its
registered seat and headquarters address
in the city of Sofia 1619, Vitosha District,
271, Tsar Boris III Blvd., Floor 5;
Inbro OOD (Ltd.), Unified
Identification Code (UIC): 121003506,
having its registered seat and
headquarters address in the city of
Sofia 1619, Vitosha municipal district,
271, Tsar Boris III Blvd., fl. 5 - direct
and indirect thr ough Unicom Consult
EOOD (Solely - owned LLC), Unified
Identification Code (UIC): 121082655;
Allterco Co Ltd, a company incorporated
under the laws of Thailand with seat and
management address: 19th Floor,
Ayothaya Tower, Soi Ratchada 18,
Ratchadapisek Road, Huaykwang,
Bangkok 10310, Thailand – indirect
through ALLTERCO JSCo (as of
31.12.2021 this circumstance is no
longer relevant )o;
BIOSEEK JSC, Unified Identification
Code (UIC): 204790412, having its seat
address and management address at: city
of Sofia 1505 Oborishte municipal
district, 42, Ilarion Dragostinov Street,
Apt. 37
Impetus Capital OOD (Ltd.), Unified
Identification Cod e (UIC): 203592737,
having its registered seat and
headquarters address in the city of
Sofia 1784, Mladost municipal district,
Mladost 1 residential district, Block of
flats 29А, Entrance А, Floor 8 - direct;
Allterco Pte Ltd, a company incorporated
under the laws of Singapore with seat
and management address: 422 Ochard
Road, #03 - 01 Claymore Connect,
Singapore 238879 - indirect through
ALLTERCO JSCo ( that circumstance
has ceased to exist after the end of the
reporting period );
BIODIT AD (PLC), Unified
Id entification Code (UIC): 203854303,
having its seat address and management
address at: city of Sofia 1756, Studentski
municipal district, 125 Kliment Ohridski
Blvd. - via IMPETUS CAPITAL OOD
(Ltd.), Unified Identification Code (UIC):
203592737
Impetus Part ners OOD (Ltd.), Unified
Identification Code (UIC): 205679429,
having its registered seat and
headquarters address in the city of
Sofia 1784, Mladost municipal district,
Mladost 1 residential district, Block of
flats 29А, Entrance А, Floor 8 - indirect
via Impetus Capital OOD (Ltd.),
Unified Identification Code/Personal
Identification Code (UIC/PIC):
203592737
Allterco SDN Bhd., Malaysia, having its
registered seat and headquarters address
in A - 3 - 35B Ioi Boulevard, Jalan Kenari
7, Bandar Puchong Jaya, 47170
Puchong, Selangor - indirect through
ALLTERCO JSCo ( th is circumstance
has ceased to exist after the end of the
reporting period ) ;
IMVENTURE I KDA, Unified
Identification Code (UIC): 204870431
Sofia 1784, Mladost municipal district,
Mladost 1 residential district, Block of
flats 29А, Entrance А, Floor 8, Apt. 38 -
as a representative representing legal
entity - IMPETUS CAPITAL OOD
(Ltd.), Unified Identification Code (UIC):
203592737
Housmeister AD, Unified
Identification Code (UIC): 203037803,
having its registered seat and
headquarters address in Sofia region,
Municipality of Kostinbrod, town of
Kostinbrod 2230, 1 Detelina Street -
direct
Allterco Robotics US (previous
company name Global Teracomm Ltd.),
USA, having its registered seat and
hea dquarters address in 5851
W.Charleston Blvd. Las Vegas, NV
89146, USA - indirect through
ALLTERCO JSCo;
IMVENTURE II KDA, Unified
Identification Code (UIC): 205737996
Sofia 1784, Mladost municipal district,
Mladost 1 residential district, Block of
flats 2 9А, Entrance А, Floor 8, Apt. 38 -
as a representative representing legal
entity - IMPETUS CAPITAL OOD
(Ltd.), Unified Identification Code/
(UIC): 203592737
UNITED COMMERCIAL OUTLETS,
Unified Identification Code (UIC):
205329927, having its registered s eat
and headquarters address in the city of
Sofia 1618, Ovcha Kupel municipal
district, Ovcha Kupel residential
district, Block of flats 48, Entrance
B(2) Apt. 47 - indirect through
ImVenture I KDA, UIC: 204870431
Allterco Trading OOD (Ltd.) (former
name Allterco Finance), Unified
Identification Code (UIC): 203348672,
having its registered seat and
headquarters address in the city of Sofia,
103, Cherni vrah Blvd. - indirect through
ALLTERCO JSCo;
UNITED COMMERCIAL OUTLETS,
Unified Identification Cod e (UIC):
205329927, having its registered seat and
headquarters address in the city of Sofia
1618, Ovcha Kupel municipal district,
Ovcha Kupel residential district, Block of
flats 48, Entrance B(2) Apt. 47
BROWSWAVE AD (PLC), Unified
Identification Code (UIC): 204458374,
having its registered seat and
headquarters address in the city of
Sofia city, Serdica municipal – indirect
through ImVenture I KDA, UIC:
204870431 and ImVenture II KDA,
UIC: 205737996
Unicom Consult EOOD (Solely - owned
LLC), Unified Iden tification Code
(UIC): 121082655, having its registered
seat and headquarters address in the city
of Sofia 1619, district of Vitosha, 271,
Tsar Boris III Blvd., Floor 5, Apt. 9 -
direct;

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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IMPETUS CAPITAL OOD (Ltd.), UIC:
203592737, having its registered s eat and
headquarters address in the city of Sofia
1784, Mladost municipal district,
Mladost 1 residential district, Block of
flats 29А, Entrance А, Floor 8
BIOSEEK JSC, Unified Identification
Code (UIC): 204790412, having its
seat address and managemen t address
at: city of Sofia 1505 Oborishte
municipal district, 42, Ilarion
Dragostinov Street, Apt. 37 - indirect
through ImVenture I KDA, UIC:
204870431
Online Media OOD (Ltd.), Unified
Identification Code (UIC): 117004285,
having its registered seat an d
headquarters address in the town of Ruse
7000, 6a, PRIDUNAVSKI Blvd.,
Entrance B (2), Floor 1, Apt. 1 - direct;
IMPETUS PARTNERS OOD (Ltd.),
Unified Identification Code (UIC):
205679429, having its registered seat and
headquarters address in the city of Sofia
1784, Mladost municipal district,
Mladost 1 residential district, Block of
flats 29А, Entrance А, Floor 8 - indirect
via Impetus Capital OOD (Ltd.), Unified
Identification Code (UIC): 203592737
Inbro OOD (Ltd.), Unified Identification
Code (UIC): 121003506, having its
registered seat and headquarters address
in the city of Sofia 1619, Vitosha
municipal district, 271, Tsar Boris III
Blvd., Floor 5 - direct;
BROWSWAVE AD (PLC), Unified
Identification Code (UIC): 204458374,
having its registe red seat and
headquarters address in the city of Sofia
city, Serdica municipal district , 14 Tajga
Str,
Impetus Capital OOD (Ltd.), Unified
Identification Code (UIC): 203592737
having its registered seat and
headquarters address in the city of Sofia
city, Mladost 1 residential district, Block
of flats 29А, Entrance А, Floor 8, Apt. 38
- direct;
„ImPuls I“ AD, UIC 206421264, Sofia
1784, district Mladost, Mladost 1, block.
29А, entrance. А, floor 8, ap. 38 – as
representative of IMPETUS CAPITAL
OOD ( Ltd.), (UIC): 203592737
Impetus Partners OOD (Ltd.), Unified
Identification Code (UIC): 205679429,
having its registered seat and
headquarters address in the city of Sofia
1784, Mladost municipal district,
Mladost 1 residential district, Block of
flats 29А, Entrance А, Floor 8 - indirect
through Impetus Capital OOD (Ltd.),
Unified Identification Code (UIC):
203592737
BIODIT AD (PLC), Unified
Identification Code (UIC): 203854303,
having its seat address and management
address at: city of Sofia 1756, Studentski
municipal district, 125 Kliment Ohridski
Blvd. - indirect through IMPETUS
CAPITAL OOD (Ltd.), Unified
Identification Code (UIC): 203592737
BIOSEEK JSC, Unified Identification
Code (UIC): 204790412, having its seat
address and managem ent address in the
city of Sofia 1505 Oborishte municipal
district, 42, Ilarion Dragostinov Street,
Apt. 37 – indirect through ImVenture I
KDA, Unified Identification Code
(UIC): 204870431
IMVENTURE I KDA, Unified
Identification Code (UIC): 204870431
Sofia 1784, Mladost municipal district,
Mladost 1 residential district, Block of
flats 29А, Entrance А, Floor 8, Apt. 38 -
indirect through Impetus Capital OOD,
UIC/PIC 203592737

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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IMVENTURE II KDA, Unified
Identification Code (UIC): 205737996
Sofia 1784, Mladost municipal district,
Mladost 1 residential district, Block of
flats 29А, Entrance А, Floor 8, Apt. 38 -
indirect through Impetus Capital OOD
(Ltd.), Unified Identification Code (UIC)
203592737
UNITED COMMERCIAL OUTLETS
Unified Identification Code (UIC):
205329927 having its registered seat and
headquarters address in the city of Sofia
1618, Ovcha Kupel municipal district,
Ovcha Kupel residential district, Block
of flats 48, Entrance B(2), Apt. 47 -
indirect through ImVenture I KDA,
Unified Identification Code (UIC):
204870431
BROWSWAVE AD (PLC), Unified
Identification Code (UIC): 204458374,
having its registered seat and
headquarters address in the city of Sofia
city, Serdica municipal district, 14,
Tayga Street - indirect through
ImVenture I KDA, Unified Identification
Code (UIC): 204870431 and ImVenture
II KDA, Unified Identification Code
(UIC): 205737996
A4E OOD (Ltd.), Unified Identification
Code (UIC): 203608928, having its
registered seat and headquarters address
in the city of Sofia city, Ovcha Kupel
district, zh.k. Ovcha Kupel 1, block 48,
entrance B, ap. 47, - indirect through
ImVenture I KDA, Unified Identification
Code (UIC): 204870431
„ImPuls I“ AD, UIC 206421264, София
1784, district Mladost, Mladost 1, block.
29А, entrance. А, floor 8, ap. 38 – as
representative of IMPETUS CAPITAL
OOD (Ltd.), (UIC): 203592737
Allterco Asia Ltd. registration number
91440300MA5GMK2T5B, registered
office number 716, Building A, XingHe
Shiji, Cai Tian road 3069, Gangxia,
Futian, Shenzhen, China – indirect
through Allterco JSCo
Allterco Europe GmbH, registration
number HRB 271205, registered office:
Lothstr. 5, 80335 München, Germany - –
indirect through ALLTERCO JSCo
5. Agreements signed in 2020 with the memb ers of the Board of Directors or related to them parties that fall outside
of the usual scope of business activity of the Company or deviate significantly from the market conditions
In 2021, no contracts were concluded with the members of the Board of Dire ctors of the Company or with related persons
who go beyond the ordinary activities of the company or significantly deviate from market conditions.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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6. The planned economic policy in the next year, incl. expected investments and staff development, expected income
from investments and development of the Company, as well as forthcoming transactions of material importance
for the Company’s activity
Changes in the economic policy of the Company in 2022 are not foreseen. The revenues of the Company will continue to
be generated mainly from dividends.
It is expected in 2022 the number of employees in the subsidiaries will increase significantly because of
1. the expanding of the market presence
2. increase of the R/D capacity of the subsidiaries
XIII. AVAILABLE BRANCHES OF THE ENTERPRISE
The Company has no registered branches.
XIV. FINANCIAL INSTRUMENTS USED BY THE COMPANY
Allterco JSCo did not use financial instruments in 2021 to hedge risks from changes in foreign currency exchange rates,
interest rates or uncertainty of cash flows. During the reporting year, the company did not perform currency risk hedging
transactions.
The Company could have exposure to liquidity, market, interest rate, currency and op erational risks arising from the use
of financial instruments.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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XV. ADDITIONAL INFORMATION UNDER APPENDIX No 2 TO ORDINANCE No 2 OF FSC
1. Information about the value and quantity on the main categories of goods, products and/or services provided,
indicating their share in the issuer's sales revenue as a whole and the changes occurring during the accounting
financial year.
Allterco JSCo does not carry out direct production activities. The production activity is carried out by the Issuer’s
subsidiaries.
2. Information on revenues broken down by category of activity, internal and external markets as well as
information on the sources of supply of materials necessary for the production of goods or the provision of
services reflecting the degree of dependence on each individual seller or buyer/user, in case the relative share
of any of them exceeds 10 per cent of the costs or revenues from sales, information is provided for each person
separately, about their share in the sales or purchases and their relations with the issuer.
Information on revenue, broken down by main categories of activities is presented in the following table:
Table No 1 4
REVENUE 2019 change 2020 cha nge 2021
Thousand
BGN %
Thousand
BGN %
Thousand
BGN
Sale of goods and production 21 039 85.9% 39 117 50.4% 58 831
Revenue from services and rents 12 279 - 41.2% 7 225 - 90.6% 678
Other operating revenue 182 456.6% 1 013 47.9% 1 498
Total operating revenue 33 500 41.4% 47 355 28.8% 61 007
Gain form operation with financial assets 8475 - 59.3% 3 446 - 92.7% 250
Total financial income 8475 - 59 .3 % 3 446 - 9 2.7 % 250
As of the end of the reporting period Allterco JSCo reported on consolidated basis operating revenue in the amount of
BGN 61 007 thousand , which is an increase of 28.8 % compared to the operating revenue on consolidated basis in 2020,
which amount ed to BGN 47 355 thousand.
The revenue from sale of devices increased by 50,4% in the reporting period compared to 2020.
In the last three periods the Company reports profit of o perations with financial assets.
3. Information about concluded significant deals
During the reporting period Allterco JSCo has conclude significant transactions within the ordinary scope of business,
which might be considered significant due to their specifics:
✓ During the reporting period Allterco JSCo has established an associated co mpany in China - Allterco Asia Ltd. with
registered office in Shenzhen. The registered capital of the new company is CNY 100 000 and the participation of
Allterco JSCo is 30 % with an option to acquire additional up to 50% and reach a controlling stake of 80%.
✓ During the reporting period Allterco JSCo, as a seller, has signed with Skylight Venture Capital Pte. Ltd., as a
buyer, an agreement for the sale of the thousand participations of Allterco JSCo in the subsidiaries ALLTERCO
PTE (Singapore), ALLTERCO S DN (Malaysia) and ALLTERCO Co., Ltd. (Thailand) (Share Purchase Agreement

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
Page 90 of 117
(SPA) as follows:
- Purchase price: EUR 2 100 000 determined after due diligence and on the basis of an independent valuation of
the sold companies
- Payment terms:
• 50% - at completion d ate after fulfilment of the seller’s obligations;
• 25% - within 18 months as of the completion date;
• 25% - within 36 months as of the completion date.
✓ Collateral: first priority pledge of the shares of the capital of ALLTERCO PTE (Singapore) and ALLTERCO S ND
(Malaysia) in favor of ALLTERCO JSCo to secure the obligation of Skylight Venture Capital Pte. Ltd. for the
differed payment of 50 % of the purchase price;
The transfer of the shares is subject to registration according to the applicable legislation in the country of registration of
the respective company.
✓ During the reporting period the Board of Directors of Allterco JSCo has approved the financing of the activity of the
associated company Allterco Asia Ltd as follows: a loan amount up to a limit of EUR 250 000, for a period of 1 year
against one - month EURIBOR, increased by 2,7 (two point seven) point of allowance per year, but not less than 2,7%
(two point seven percent) total annual interest, which is accrued on a 3 - month basis to the utilized amoun t of the loan
limit. As of the date of the report, no cash have been transferred to the associated company in connection with the
approved financing.
✓ In reference to additional cash contributions provided by Allterco JSCo to its subsidiary Allterco Trading EOOD in
the amount of 900 000, whereas as of the end of the reporting period the term of the additional cash contribution
provided to Allterco Trading EOOD is extended by another one year.
✓ Allterco JSCo has founded a subsidiary in Germany – Allterc o Europe GmbH. The German company has its seat and
registered office in Munich, Germany and capital of EUR 500 000, 100 % held by Allterco JSCo
4. Information on transactions concluded between the Issuer and related parties during the reporting period,
propo sals for such transactions as well as transactions that are outside its ordinary activity or materially
deviate from the market conditions, where the issuer or its subsidiary is a party with indication of the value
of the transactions, the nature of the re lationship and any information necessary to assess the impact on the
Issuer's financial position.
During the reporting period Allterco JSCo did not enter into large transactions with related party, nor did it make or
received offers for such transactions.
During the reporting period the Company did not enter into any related party transactions within the meaning of IAS 24,
except for the following transactions entered into with subsidiaries that are in the ordinary course of business, which
include:
✓ The Co mpany uses cars provided by its subsidiary at a total cost of BGN 17 thousand.
✓ Allterco JSCo has extended the term of the cash contribution of EUR 900 000, that it provided to the subsidiary
Allterco Trading EOOD in 2019. The revenue from interest for the period amounted to BGN 18 thousand.
✓ the Board of Directors of Allterco JSCo has approved the financing of the activity of the associated company
Allterco Asia Ltd as follows: a loan amount up to a limit of EUR 250 000, for a period of 1 year against one -

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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mo nth EURIBOR, increased by 2,7 (two point seven) point of allowance per year, but not less than 2,7% (two
point seven percent) total annual interest, which is accrued on a 3 - month basis to the utilized amount of the loan
limit. As of the date of the report, no cash have been transferred to the associated company in connection with
the approved financing.
All intercompany transactions have been eliminated in preparing the consolidated financial statements
5. Information about events and indicators of unusual for the Issuer nature that have a significant impact on its
activities and its realized revenues and expenses; assessing their impact on results in the current year.
During the reporting period there were no events or indicators in unusual nature f or Allterco JSCo. Allterco JSCo is a
joint stock company - holding, whose scope of business includes acquisition, management, assessment and sale of
participations in Bulgarian and foreign companies. Within the scope of its business in 2020, the Company ha s carried out
a transaction for sale of participations in companies outside its economic group, namely:
✓ Sale of Allterco’s shares in the subsidiary companies ALLTERCO PTE (Singapore), ALLTERCO SDN (Malaysia)
and ALLTERCO Co., Ltd. (Thailand) to Skylight Ve nture Capital Pte. Ltd. under the following conditions
- Purchase price: EUR 2 100 000 determined after due diligence and on the basis of an independent valuation of
the sold companies
- Payment terms:
• 50% - at completion date after fulfilment of the seller’s obligations;
• 25% - within 18 months as of the completion date;
• 25% - within 36 months as of the completion date.
- Collateral: first priority pledge of the shares of the capital of ALLTERCO PTE (Singapore) and ALLTERCO
SND (Malaysia) in favor of ALLTERCO JSC o to secure the obligation of Skylight Venture Capital Pte. Ltd.
for the differed payment of 50 % of the purchase price;
The transfer of the shares is subject to registration according to the applicable legislation in the country of registration of
the re spective company
✓ Provided financing for the operations of the associated company Allterco Asia Ltd. with the following parameters:
limit of the financing extended - 250 000 EUR, time period - 1 year, interest rate – 1 - month EURIBOR+ 2.7% (two
point seven) on annual base, but not less than 2.7% (two point seven percent) annual interest rate which is calculates
on 3 - month base on the outstanding part of the loan. As of the date of this report no funds had been transferred to the
associated company.
6. Information about off - balance - sheet transactions - nature and business purpose, indication of the financial
impact of transactions on the business if the risk and benefits of those transactions are material to the
company and disclosure of such information is material to the Issuer's financial condition.
During the reporting period the Company did not enter into transactions that were conducted off - balance sheet beside
those reported under item 7 Conditional Liabilities of the consolidated financial stateme nt of the Company.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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7. Information on stake holdings of the Issuer, its main investments in the country and abroad (in securities,
financial instruments, intangible assets and real estate) as well as investments in equity securities outside its
Group of companies within the meaning of the Accountancy Act and the sources/ways of financing.
As of the end of the reporting period, the economic group of Allterco JSCo consists of the following subsidiaries:
The company holds 695 411 shares of the capital of Victory Partners VIII Norway Holding AS (current name Link
Mobility Group Holding ASA, "Link Holding"). The specified number of shares represents the balance of a total of 1 345
180 shares received as part (20%) of the price, under the Share Purchase Agree ment (SPA) dated 29.06.2019 for the sale
of the telecommunications business of Allterco JSCo in Europe, concluded with Link Mobility Group AS. As of the date
of this Report there are no restrictions on the free disposal of the specified number of shares.
D uring the reporting period Allterco JSCo has participated in the establishment of a company (associated company) in
China, Allterco Asia Ltd. The investment is BGN 8 thousand (30% of the company’s capital). Allterco JSCo holds an
option to acquire addition al up to 50% and reach a controlling stake of up to 80% in case of good development of the
project.
8. Information about loan agreements concluded by the company or its subsidiary or parent company, in their
capacity of borrowers, with specification of their terms, including deadlines for repayment, as well as
information on guarantees and commitments.
Allterco JSCo is a borrower under a Mortgage (investment) loan agreement dated 25.08 .2017, concluded with
Raiffeisenbank Bulgaria EAD, se cured by a guarantee of the subsidiary Allterco Properties EOOD.
Allterco JSCo has assumed joint liability and a guarantee obligation for securing two bank financing agreements
concluded by its subsidiary Allterco Robotics EOOD with Raiffeisenbank Bulgaria EAD.
Table 15
Contract Annex Creditor Debtor Joint debtor/
Guarantor
Amount/
Limit
Financial
conditions Term
COLLATERAL
provided by the
borrower
Investment
credit
25.08 2017
Contract
pursuant to
Annex
1/
31.10.2018
Allterco
JSCo
Tera
Communications AD
- joint debtor
(excluded)
EUR
1 620 000
Fixed interest
rate for the
whole period
3% annually;
Management fee
10.05.2029
Mortgage on real
estate, owned by
Allterco Properties
EOOD;

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
Page 93 of 117
Art. 114,
Paragraph 10
of the Public
Offering of
Securities Act
Raiffeisen
bank
Bulgaria
EAD
Allterco Properties
EOOD - joint debtor
Pledge of receivables
on all accounts of the
group opened with
the bank;
Pledge under
Financial Collateral
Contracts Act;
Overdraft
30.09.2019 -
contract in
accordance
with Art. 114,
Paragraph 10
of the Public
Offering of
Securities Act
Annex
1/
28.08.2020
Raiffeisen
bank
Bulgaria
EAD
Allterco
Robotics
EOOD
Allterco JSCo -
guarantor
EUR
1 000 000
1 - month
EURIBOR,
increased by 2.5
percentage
points, but not
less than 2.5%
Management
fee;
Commitment
fee;
Guarantee issue
fee;
29.09. 2022 Pledge of receivables
on bank accounts;
Contract for
standard
investment No
2757 dated
28.09.2020
none DSK Bank
AD
Allterco
Properties
EOOD
Allterco Trading
EOOD – joint debtor
EUR
450 000
Annual interest
formed by
variable interest
rate 1 - month
EURIBOR+2.1
%, but not less
than 2.1%;
Annual
m anagement
fee;
28.09.2024
Real estate mortgage,
owned by Allterco
Properties EOOD;
Pledge on
receivables on bank
accounts of Allterco
Properties EOOD
and Allterco Trading
EOOD in DSK Bank.
9. Information on loan agreements concluded by the Issuer, its subsidiary or parent company, in their capacity
as lenders, including the provision of guarantees of any kind, including to related parties, with specification
of their special terms, including the final payment deadlines, and the purpose for which they we re granted.
In 2019 Allterco JSCo has provided to its subsidiary Allterco Trading EOOD additional cash contributions in the amount
of EUR 900 000 each, for a period of 1 year, against an annual interest rate of 1%, the interest being accrued on base of
360 days. The interest income on provided additional cash contributions amounts to BGN 18 thousand. At the end of the
reporting period the term of the additional cash contribution provided to Allterco Trading EOOD was extended by another
one year. The interes t rate not paid at the end of the reposting period amounts to BGN 4 thousand.
The Company has decided on the financing the activity of the associated company Allterco Asia Ltd as follows: a loan
amount up to a limit of EUR 250 000, for a period of 1 year a gainst one - month EURIBOR, increased by 2,7 (two point
seven) point of allowance per year, but not less than 2,7% (two point seven percent) total annual interest, which is accrued
on a 3 - month basis to the utilized amount of the loan limit. As of the date o f the report, no cash have been transferred to
the associated company in connection with the approved financing
Allterco JSCo did not conclude other loan agreements in its capacity of a lender.
The subsidiaries have provided guarantees in the form of joint liability under bank financing agreements, as indicated in
the table in the foregoing item 8.
10. Information on the use of funds from new issue of securities during the reporting period.
In 2020, the Company issued new securities as a result of a successful capital increase through an initial public offering.
In the course of the offer were subscribed and paid 2 999 999 (two million nine hundred and ninety - nine thousand nine
hundred and ninety - nine) dematerialized ordinary registered voting shares with a nom inal value of one lev.

ALLTERCO JSCo
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CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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As of the end of the reporting period, the Company has spent part of the funds from the new issue of shares, as follows:
✓ Expansion and building of the distribution network: participation in local and international exhibitions and
re gistration of a subsidiary in Germany which will build on the distribution network and develop new sales
channels in Western Europe.;
✓ Working capital: increase inventories of production and of critical electronic components for the
manufacturing process.
✓ R&D development: increase of IT and engineering staff; device certification.
11. Comparison between the achieved financial results presented in the financial statements for the financial year
and previously published forecasts.
Allterco JSCo has not published forecasts for the current financial year on consolidated basis.
In relation to the Prospectus for public offering of shares from the capital increase of Allterco JSCo, approved by the
Financial Supervision Commission with Resolution No 148 dated 18.02.2020, the Company has presented new forecasts
for the period 2020 - 202 4 which are included in the Registration document, part II of the Prospectus , available on the
website of the issuer at https://allterco.com/en/IPO_2020_PROSPEKT and on the website of the investment intermediary
Karoll AD at https://karollbroker.bg/bg/cap - increase - allterco .
12. Analysis and evaluation of the policy on financial resources management, specifying the capabilities for
servic ing the obligations, possible threats and measures that the Issuer has undertaken or is about to
undertake to mitigate the risks.
ALLTERCO JSCo carries out its operational activities in a way that the management of the two - point financial resources
is excl usively subordinated to the maintaining of such a capital structure that will allow the company to combine the
lower risk of using only own funds with the higher efficiency and flexibility of cash flow under conditions of debt
financing so that the Company is able at any time to switch from one type of financing to another, depending on its
specific needs.
In connection with the epidemiological situation in the Republic of Bulgaria and the related measures to combat the
COVID 19 pandemic, the Company has ta ken appropriate measures to limit the impact of this situation on the business
operation and to ensure continuity of the work and production processes with minimal delay.
Impact of COVID 19 on the business activity:
In 2021, the management continued to suc cessfully implement certain stabilization measures to limit potential negative
impact on the Company's personnel and/or financial position. As a result of these measures (introduction of a hybrid work
option for Group employees; timely resourcing of key pr oduction components), the Group is reporting a positive trend in
its business development and expects this trend to continue in 2022.
13. Assessment of the possibilities for realization of investment intentions, indicating the amount of the available
funds an d stating the possible changes in the structure of financing this activity.
In 2022 the Company plans to continue investing in the development of Internet of Things through its subsidiaries.
The investment program will be funded with Company’s own cash and raised funds, if necessary.

ALLTERCO JSCo
Unified Identification Code (UIC): 201047670
CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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14. Information on changes that occurred during the reporting period in the key management principles of the
Company and its subsidiaries within the meaning of the Accountancy Act.
During the reporting period, there were no changes in the basic principles for managing the Company and its Group of
companies.
15. Information on the main features of the internal control and the risk management system applied by the
Company in the financial reporting.
A general description of the internal control and risk management system
The Company has a system of internal control and risk management ("the system") that guarantees the effective
functioning of the reporting and disclosure systems as well as an audit committee. The system is built and functioning in
order to identify the risks associated with the Company's activities and their effective management. The Board of Directors
has the primary responsibility and role in establishin g the internal control and risk management system. It performs both
managing and guiding function as well as ongoing monitoring.
The ongoing monitoring by the management consists of assessing whether the system is still appropriate for the company
in a cha nged environment, whether it operates as expected and whether it adapts successfully to the changed conditions.
The evaluation of selected areas is in line with the company's priorities. The evaluation is also commensurate with the
specifics of the company and the impact of the identified risks.
The Board of Directors monitors the main features and characteristics of the system, including identified incidents and
the respective applied corrective actions.
The Audit Committee assists the Board of Directors in the exercise of their control functions and powers with regard to
the financial reporting process, the internal control system, the audit process and monitoring on compliance with the
provisions of applicable national and European legislation, as well a s the company's internal policies. The Audit
Committee holds regular meetings, fulfilling the functions assigned to it by law and the General Meeting of Shareholders
in accordance with the adopted Statutes.
Control environment
The control environment inclu des the functions of general management, as well as the attitude, awareness and actions of
the corporate management pertaining to internal control.
• Commitment for competence. The Board of Directors of the company, as well as those involved in the internal
control and risk management process, have the relevant knowledge and skills necessary to perform the tasks that
their subordinates perform. The executive members of the Board of Directors of the company take care to monitor
the levels of competence required for the specific jobs and the ways in which those competences become
necessary requisites.
• Participation of persons involved with general management. The control environment is greatly influenced
by the people involved in the general management, namely the Board of Directors. The responsibilities of the
members of the Board of Directors are stated in the Statutes of the company and the management contr acts. In
addition, the Executive Members of the Board of Directors are also responsible for the supervision of the
effective functioning of the early warning procedures and of improving the company's internal control.
• Philosophy and operational style of t he management. The philosophy and operational style of the

ALLTERCO JSCo
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management cover a wide range of characteristics. The attitudes of the members of the Board of Directors and
their actions in relation to financial reporting are manifested through the choice of mo re conservative accounting
principles.
• Organizational structure Establishing an appropriate organizational structure involves defining an appropriate
number of hierarchical levels and defining the basic powers and responsibilities for each of these levels. The
Board of Directors assesses the appropriateness of the organizational structure of the company, taking into
consideration the size and nature of the activities performed.
• Assignment of powers and responsibilities . When assigning powers and responsibi lities of the employees in
the companies, the management shall take into account the applicable business practices, knowledge and
experience of employees and available resources available in the Company.
• Policies and practices related to human resource. W hen recruiting staff, the Executive members of Board of
Directors focus on qualifications, previous professional experience, past accomplishments, and evidence of
integrity and ethical conduct. The purpose of corporate management is to hire competent and r eliable employees.
Risk assessment process for the Company
The process of risk assessment is the basis on which the Board of Directors of the Company determines the risks to be
managed.
The Board of Directors of the Company identifies the following types of risk that affect the Company and its activities:
general (systematic) and specific (non - systematic) risks.
Systematic risks are related to the macro environment in which the Company operates, which is why in most cases they
cannot be controlled by the m anagement team.
Non - systematic risks are directly related to the activities of the Company and depend mainly on corporate governance.
To minimize them, we rely on increasing the efficiency of internal company planning and forecasting, which provides
opport unities to overcome possible negative consequences of a risky event.
Each of the risks related to the country - political, economic, credit, inflation, foreign exchange, has its own significance,
but the interaction between them forms a comprehensive pictu re of the main economic indicators, market and competitive
conditions in the country in which each company operates.
A detailed description of the risks typical for the activity of ALLTERCO JSCo is presented in the section MAIN RISKS,
WHICH THE COMPANY FAC ES in this activity report.
16. Information about the changes in the Board of Directors of the Company in 2020
During the reporting period, no changes were made to the Board of Directors of the Company and with a decision of the
General Meeting of Sharehold ers dated 21.09.2020 the mandate of the Board of Directors with the same members was
extended with a new 5 - year term.
As of the end of the reporting period, the members of the Board of Directors are:
• Dimitar Stoyanov Dimitrov
• Svetlin Iliev Todorov
• Niko lay Angelov Martinov

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CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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As of the end of the reporting period, there has been a change in the composition of the Board of Directors, with the
resolution of the General Meeting of Shareholders of 08.04.2022 changing the number of the Board members from three
to five, where Mr. Wolfgang Kirsch and Mr. Gregor Bieler join to the current members.
Pursuant to the resolution of the General Meeting of Shareholders at its first meeting held on 08.04.2022. the Board of
Directors elects from among its members the following executive members, Chairman and Deputy - Chairman:
• Gregor Bieler - Chairman;
• Nikolay Martinov - Deputy Chairman;
• Dimitar Dimitrov - Executive Director and Representative;
• Wolfgang Kirsch - Executive Director and Representative;
• Svetlin Todorov - Member of the Board of Directors and Representative;
17. Information on the amount of remuneration, rewards and/or additional benefits of each member of the Board
of Directors for the financial year paid by the Company and its subsidiaries, regardless of wheth er they were
included in the Company's expenses or are attributable to distribution of profits, including:
A) received amounts and non - monetary remunerations
During the reporting period, the members of the Board of Directors received remuneration in the to tal amount of BGN
130 in accordance with the effective Remuneration Policy.
• Dimitar Stoyanov Dimitrov - BGN 48 thousand
• Svetlin Iliev Todorov - BGN 48 thousand
• Nikolay Angelov Martinov - BGN 34 thousand
During the reporting period the following members of the Board of Directors received remuneration from subsidiaries:
• Dimitar Stoyanov Dimitrov - BGN 488 thousand
• Svetlin Iliev Todorov - BGN 353 thousand
The members of the Board of Directors did not receive any non - cash benefits during the reporting period.
B) contingent or deferred wages arising during the year, even if the remuneration is due at a later date;
As of the end of the reporting period, Allterco JSCo has no conditional or deferred remunerations incurred during the
year, including remuneration that is due at a later date.
C) an amount owed by the Company or its subsidiaries for the payment of pensions, retirement benefits or other
similar benefits.
As of the end of the reporting period, the Company does not report amounts due for pa yment of pensions, retirement
benefits or other similar benefits.
18. Information about shares owned by members of the Board of Directors, procurators and senior management,
including the shares held by each of them as a percentage of the shares of each class , as well as options
provided by the Company on securities - the type and size of the securities on which the options are issued,
the exercise price, the purchase price, if any, and the term of the options.
As of the end of the reporting period, the shares held by members of the Board of Directors of ALLTERCO JSCo are:

ALLTERCO JSCo
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CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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Table No 1 6
Name PERCENTAGE OF THE CAPITAL
Svetlin Todorov 32,48 %
Dimitar Dimitrov 32,48 %
Nikolay Angelov Martinov* 0 %
* * Nikolay Martinov has no direct interest in the capital of the Issuer. The companies Unicom Consult EOOD, in which
he is the sole owner of the capital and manager, Impetus Capital OOD and Impetus Partners OOD, in which he is a partner
respectively with 50% and 43,75 % of the capital and manager, as well as Imventure I KDA and Imvencher II KDA, in
which he is a representative of the legal entity - "IMPETUS CAPITAL" OOD, have respectively: "Unicom Consult
“EOOD – 84,750 shares (0.47%), Impetus Capital OOD 27,000. shares and 162,000 voting rights (0.9%), Im petus
Partners OOD 405,000 shares (2.25%) ImVenture I KDA 123,288 shares (0.68%), Imventure II KDA - 68,493. shares
(0.38%) in the capital of Allterco JSCo and a total 708,531 number of shares and 843,531 voting rights (4.686%) of the
voting rights in its General Meeting.
19. Information for the commitments known to the Company (including after the end of the financial year), which
in the future may result in changes in the relative portion of shares or bonds held by present shareholders or
bondholders.
The company is not aware of any commitments that may in the future result in a change in the number of shares or bonds
held by current shareholders.
In October 2020, the majority shareholders and members of the Board of Directors - Svetlin Ili ev Todorov and Dimitar
Stoyanov Dimitrov concluded an Agreement for blocking the currently owned by them a total of 11 552 240 shares of
the company's capital for a period of 3 years, as of the date of entry of the capital increase in the Commercial Regist er.
According to the terms of the agreement, the 6 - months lock - up period expired as at the end of the reporting period and
the majority shareholders are currently entitled to trade up to 7% of their shareholdings. Svetlin Iliev Todorov and Dimitar
Stoyanov Dimitrov have agreed between themselves and in favor of the public listed company. The agreement is still in
force during the reporting period.
20. Information on pending litigation, administrative or arbitration proceedings concerning payables or
receivable s of the Company amounting to at least 10 percent of its equity.
In connection with the sale in 2019 of five subsidiaries to Link Mobility Group AS, the buyer did not fulfil its obligation
to pay the remaining 20% of the price (BGN 3 053 thousand), which w as due in August 2021 and as at the end of the
reporting period was not paid. Allterco JSCo has decided to undertake the necessary measures for collection of the due
amount in accordance with the procedure agreed under the Share Purchase Agreement and name ly – by filing a law suit
before the Vienna International Arbitral Center
21. Information on the Investor Relations Director, including telephone and correspondence address
For Bulgaria
Denitsa Stefanova
Tel: +359 2 9571247 e - mail: investors@allterco.com
For Germany
CROSS ALLIANCE communication GmbH, Sven Pauly

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CONSOLIDATED REPORT ON BUSINESS ACTIVITIES FOR 2021
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Tel: +49 89 125 09 0331, E - Mail: sp@crossalliance.de
www.crossalliance.de
22. Non - financial declaration under Article 41 of the Accounting Act - for financial statements on an individual
basis, respectively under Article 51 of the Accounting Act - for financial statements on a consolidated basis,
where applicable .
The Company has no obligation for non - financial reporting.
23. Other information at the discr etion of the Company
Other circumstances which the Company considers may be relevant to the investors in deciding whether to buy, sell or
continue to hold shares are disclosed publicly, including in the Company's Report on Business Activities and the Notes
to the financial statements.
XVI. CHANGES IN THE PRICE OF THE COMPANY’S SHARES
Table 17
Date Volume Turnover Highest
value
Lowest
value
Opening
value
Closing value
30.12.2021 184925 4 277 266,800 25,400 19,700 24,800 24,800
30.11.2021 227350 5 662 099,900 28,800 19,700 19,700 25,200
29.10.2021 130242 2 481 955,300 20,600 17,200 20,600 19,700
30.09.2021 96202 1 786 979,700 20,800 17,100 17,400 20,600
31.08.2021 51497 900 197,700 17,900 16,900 17,700 17,400
30.07.2021 32713 578 825,400 18,400 16,600 17,100 17,700
30.06.2021 87283 1 476 797,500 17,900 15,800 15,900 17,100
31.05.2021 68960 1 026 272,200 16,000 13,700 14,400 15,900
29.04.2021 177039 2 312 406,600 14,900 11,000 11,100 14,400
31.03.2021 150097 1 477 504,850 11,100 9,000 9,200 10,900
26.02.2021 131599 1 190 116,700 9,450 8,750 8,850 9,200
29.01.2021 1040688 7 017 515,900 9,250 6,500 6,850 8,700
Source: Investor.bg
Information on the trading in the shares of Allterco JSCo during the reporting period on the Frankfurt Stock Exchange
is available at https://w ww.boerse - frankfurt.de/equity/allterco - jsco/price - history/historical - prices - and - volumes
Date: 29.04. 2022
Executive Director:
/Dimitar Dimitrov/

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CORPORATE GOVERNANCE DECLARATION
OF ALLTERCO JSCo
IN ACCORDANCE WITH THE PROVISIONS OF
ART. 100N, PARA. 8 OF THE PUBLIC OFFERING OF SECURITIES ACT
1. Information whether ALLTERCO JSCo complies, where appropriate, with the Corporate Governance
Code, approved by the Deputy Chairman, or another corporate governance code
ALLTERCO JSCo and its management comply, where appropriate, with the National Corporate Governance Code.
Some of the reco mmendations of the National Code are not yet fully implemented by the corporate management of
the company, but the Board of Directors is committed to continue to bring the activities of ALLTERCO JSCo in line
with them in 2022.
ALLTERCO JSCo is part of a gr oup of companies within the meaning of §1, item 2 of the Additional Provisions of
the Accounting Act and is a parent company that directly holds more than 50% of the votes in the general meeting of
several subsidiary companies.
The subsidiaries of ALLTERCO JSCo are not public listed companies and in their activity, they do not apply the
principles and provisions of the National Corporate Governance Code, with the exception of the provisions concerning
the internal control and risk management systems, which are applied at Group level. Many of the provisions of the
Co de are inapplicable due to the legal and organizational form of these companies and the specifics of the sole
proprietorship.
2. Information on the corporate governance practices applied by ALLTERCO JSCo in addition to the National
Corporate Governance Co de
ALLTERCO JSCo does not apply other corporate governance practices in addition to the National Corporate
Governance Code.
3. Explanation by ALLTERCO JSCo which parts of the National Corporate Governance Code are not observed
and what are the reasons for this are
In 2021, the activity of the Board of Directors of ALLTERCO JSCo was carried out in full compliance with the
regulatory requirements set out in the Public Offering of Securities Act and the acts on its implementation in the
Statutes of the Compan y. The corporate management of ALLTERCO JSCo considers that there are still parts of the
National Corporate Governance Code that the Company does not comply with, but in 2021 the management will
continue to perform all necessary legal and factual actions t o bring the activity in line with the principles and
recommendations of the Code, as well as best practices in the field of corporate governance.
The Code is applied on the basis of the "observe or explain" principle . This means that the Company complies w ith

CORPORATE GOVERNANCE DECLARATION
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the Code, and in case of deviation, its management should clarify the reasons for this.
І. Chapter One – Corporate management
ALLTERCO JSCo is a Company with a one - tier management system and is managed by a Board of Directors.
Functions and obligat ions
The Board of Directors directs and controls independently and responsibly the activity of the Company in accordance
with the established vision, goals, strategies of the Company and the interests of the shareholders.
The Board of Directors monitors t he results of the Company's activities on a quarterly and annual basis and, if
necessary, initiates change in the management of the activity.
The Board of Directors treats all shareholders equally, acts in their interest and with the care of a good merchant.
The members of the Board of Directors are guided in their activities by the generally accepted principles of integrity
and managerial and professional competence. The Board of Directors has not adopted a Code of Ethics.
The Board of Directors has built and ensured the functioning of a risk management system, including for internal
control and internal audit.
The Board of Directors has ensured and controls the integrated operation of the accounting and financial reporting
systems.
The Board of Dire ctors provides guidelines, approves and controls the implementation of the company's business plan,
substantial transactions, as well as other activities established in its bylaws.
In accordance with the requirements of the Public Offering of Securities Ac t, the Board of Directors monitors all
substantial transactions and approves them. If there are transactions, which individually or collectively exceed those
specified in Art. 114, para. 1 of the Public Offering of Securities Act thresholds, the Board of D irectors prepares a
motivated report and adopts a decision to convene a General Meeting of Shareholders, at which it is authorized by the
shareholders to carry out these transactions.
The Board of Directors reports on its activities to the General Meeting of Shareholders, submitting the annual activity
report and the report on the implementation of the remuneration policy for approval by the shareholders.
Election and dismissal of members of the Board of Directors
The General Meeting of Shareholders elec ts and dismisses the members of the Board of Directors in accordance with
the law and the Statutes of the Company, as well as in accordance with the principles of continuity and sustainability
of the work of the Board of Directors.
In case of proposals for election of new members of the Board of Directors, the principles of compliance of the

CORPORATE GOVERNANCE DECLARATION
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candidates’ competence with the nature of the National Corporate Governance Code in the activity of the Company
are observed.
All members of the Board of Directors meet the legal requirements for holding office. The functions and obligations
of the corporate management, as well as its structure and competence are in accordance with the requirements of the
Code.
The contracts for assignment of the management , concluded with the members of the Board of Directors, define their
obligations and tasks, the criteria for the amount of their remuneration, their obligations for loyalty to the company
and the grounds for dismissal.
During the reporting financial year, ALLTERCO JSCo implemented the Remuneration Policy of the members of the
Board of Directors, adopted in 2021 by of ALLTERCO JSCo.
The remuneration of the members of the Board of Directors and information on their amount is duly disclosed in the
activity rep ort of the Board of Directors as of 31.12.2021, as well as in the Report on the application of the
Remuneration Policy of the members of the Board of Directors, which are an integral part of the annual financial
report of the Company.
Structure and compet ence
The number of members and the structure of the Board of Directors are determined in the Statutes of the Company.
The composition of the Board of Directors is structured in a way that guarantees the professionalism, impartiality and
independence of it s decisions in relation to the company management. The functions and obligations of the corporate
management, as well as its structure and competence are in accordance with the requirements of the Code.
The Board of Directors shall ensure the proper distri bution of tasks and responsibilities between its members.
The independent members of the Board of Directors of ALLTERCO JSCo control the actions of the executive
management and participate effectively in the work of the company in accordance with the inter ests and rights of the
shareholders.
The Chairperson of the Board of Directors is not an independent director. Given the existing capital structure of the
Company, the members of the Board of Directors consider it appropriate that the Chairperson of this b ody should not
be an independent director.
The competencies, rights and obligations of the members of the Board of Directors follow the requirements of the
law, the by - laws and the standards of good professional and managerial practice.
The members of the Board of Directors have the appropriate knowledge and experience required by the position they
hold. Information about the professional qualification and experience is disclosed during the election of the members
of the Board of Directors with the material s for the General meeting of the shareholders.
After the election of new members of the Board of Directors, they get acquainted with the main legal and financial

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issues related to the Company's activities.
Improving the qualification of the members of the Board of Directors is their constant commitment.
The members of the Board of Directors have the necessary time to perform their tasks and duties, even though the
statutes of the Company do not determine the number of companies in which the members of the B oard of Directors
may hold managerial positions. This circumstance is taken into account in the proposals and election of new members
of the Board of Directors.
The election of the members of the Board of Directors of the Company is performed by means of a transparent
procedure, which provides, among other things, timely and sufficient information about the personal and professional
qualities of the candidates for members. As part of the materials for the General Meeting, at which the election of a
new memb er of the Board of Directors is proposed, all declarations required by the POSA and the Commercial Law,
a criminal record certificate and a professional biography of the candidate for elected position are to be submitted.
When electing members of the Board of Directors, the candidates confirm with a declaration or in person to the
shareholders the accuracy of the submitted data and information. The election procedure is conducted by show of
hands and counting the votes "For", "Against" and "Abstentions". Th e voting results are announced through the
minutes of the General Meeting of Shareholders. The number of consecutive terms of office of the members of the
Board of Directors ensures efficient operation of the Company and compliance with the legal requireme nts. The
statutes of the Company do not provide for a limit on the number of consecutive mandates of the independent
members, but this circumstance is observed in the proposal for election of independent members.
Remuneration
The Board of Directors has developed a clear and specific policy for the remuneration of the members of the Board
of Directors, which was approved by the Annual General Meeting of Shareholders in 2017, amended in 2021 by the
Annual General Meeting of Shareholders of AL LTERCO JSCo and sets the principles for forming the amount and
structure of the remuneration.
The remuneration of the Executive Member of the Board of Directors consists of a basic remuneration and additional
incentives. The additional incentives are subje ct to clear and specific criteria and indicators regarding the Company's
results and/or the achievement of goals set in advance by the Board of Directors.
Pursuant to the Remuneration Policy adopted by the General Meeting of Shareholders, the Company may p ay
executive members of the Board of Directors ( members of the Board of Directors representing the Company in its
relations with third parties, as recorded in the Commercial Register with the Registry Agency ) variable remuneration
in shares in order to dir ectly engage management in the achievement of long - term corporate objectives. Variable
remuneration in shares is not provided for non - executive members of the Board of Directors. The share - based
remuneration of the Company, the criteria for their grant and their amounts are determined on the basis of a Share -
based Remuneration Scheme approved by the General Meeting of Shareholders, as adopted in 2021.

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The independent members of the Board of Directors receive remuneration in accordance with the principles fo r
forming the amount and the structure of remuneration set out in the Remuneration Policy adopted by the Annual
General Meeting of the Shareholders in 2021.
As mentioned above, the disclosure of information on the remuneration of the members of the Board o f Directors is
carried out in accordance with the legal norms and bylaws of the Company - by disclosing in the Annual Report on
the Business Activities and the Report on the Application of the Remuneration Policy for the members of the Board
of Directors. In this way, the shareholders have easy access to the policy observed by the company regarding the
permanent and additional remuneration to the members of the Board of Directors.
Conflict of interests
The members of the Board of Directors avoid and do not allow real or potential conflicts of interest. During the
reporting period, no transactions have been concluded between the company and members of the Board of Directors
or persons related to them.
The members of the Board of Directors immediately disclo se conflicts of interest and provide the shareholders with
access to information on transactions between the Company and members of the Board of Directors or persons related
to them by presenting the declaration under Art. 114b of the POSA.
The Board of Di rectors has not established a specific procedure for avoiding conflicts of interest in transactions with
interested parties and disclosing information in the event of such, but controls the conclusion of significant transactions
through voting and approval of such transactions.
ІІ. Chapter Two – Audit and internal control
The Board of Directors is assisted by an Audit Committee.
The Board of Directors and the Audit Committee ensure compliance with the applicable law regarding the independent
financial audit . The rotation principle is applied in the proposals and election of an external auditor.
The Audit Committee oversees the internal audit activities and monitors the overall relationship with the external
auditor, including the nature of non - audit services provided by the Company's auditor.
The Company has established and operates an internal control system, which includes identifying the risks associated
with the Company's activities and supporting their effective management. It also ensures the effective functioning of
the accountability and information disclosure systems. A description of the main characteristics of the internal control
and risk management systems is presented in item 4 of this corporate governance declaration.
ІІІ. Chapter Three – Protec tion of the shareholders’ rights
The Board of Directors ensures equal treatment of all shareholders, including minority and foreign shareholders,
protects their rights and facilitates exercising them within the scope permitted by the applicable law and in accordance

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with the provisions of the Company's statutes.
In the reporting period, the Company held one regular and one extraordinary General Meeting of Shareholders,
complying with all the requirements of Art. 115 et seq. of the POSA, announcing the deci sion for its convention and
publishing the invitation together with the materials thereto in the manner specified by the law. The shareholders were
guaranteed the opportunity to add new items to the agenda under Art. 223a of the CA. The Statutes of the Com pany
provide for the invitation to the General Meeting to contain the information required under the Commercial Act and
POSA, as well as additional information on exercising the right to vote and the possibility to add new items to the
agenda under Art. 22 3a of the CA.
The corporate management ensures that all shareholders are informed about their rights through the information
published on the Company's website, the announced Statutes of the Company and the invitation for each specific
General Meeting of S hareholders together with the materials to it.
General Meeting of Shareholders
All shareholders are informed about the rules according to which the General Meetings of Shareholders are convened
and held, including the voting procedures through the Statut e of the Company and the invitation for each specific
general meeting of shareholders.
The Board of Directors provides sufficient and timely information on the date and place of the General Meeting, as
well as complete information on the issues to be discu ssed and resolved at the Meeting.
The invitation and materials for the General Meeting of Shareholders are announced through the selected media
agencies and reach the public, the Financial Supervision Commission and the regulated securities market. After
p resenting the invitation and the materials for the General Meeting of Shareholders, they are also made available on
the Company's website.
Shareholders with voting rights have the opportunity to exercise their voting rights at the General Meeting of the
Co mpany in person or through representatives and voting by correspondence might be allowed for a specific General
Meeting of the Shareholders.
As part of the materials for the General Meeting of Shareholders, the Board of Directors provides a sample power of
attorney. The Company indicates the Rules for voting by proxy and the Rules for voting by correspondence (when
applicable) in the content of the invitation or as a separate document - part of the materials to it.
The Board of Directors has undertaken all necessary actions to bring the Company's activities in line with the
recommendations of the Code.
The Statutes of the Company allow exercising the right to vote by electronic means and/or by correspondence by
deci sion and rules determined by the Board of Directors in the invitation to convene a General Meeting.
The Board of Directors exercises effective control by creating the necessary organization for the voting of the
authorized persons in accordance with the in structions of the shareholders and in the ways permitted by law. The

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Board of Directors appoints a mandate commission, which registers the shareholders for each specific General
Meeting and proposes to the General Meeting to elect a Chairperson, Secretary and Vote Tellers. The management of
the General Meeting strictly monitors the lawful conduct of the General Meeting, including the manner of voting of
the authorized persons. When differences are noticed in the will of the principal and the vote of the aut horized person,
this circumstance is entered in the minutes and the will of the principal is taken into account accordingly.
The Board of Directors has not prepared and adopted a specific policy for the organization and holding of ordinary
and extraordinar y General Meetings of Shareholders, but at the same time monitors compliance with the principles of
equal treatment of all shareholders and the right of each shareholder to express their opinion on the items on the agenda
of the General Meeting. The Board of Directors prepares Rules for voting by proxy and Rules for voting by
correspondence (when applicable) to the materials for convening General Meetings.
The Board of Directors organizes the procedures and order for holding the General Meeting of Sharehold ers in a way
that does not complicate or increase the cost of voting unnecessarily.
The Board of Directors does not encourage the participation of shareholders in the General Meeting of Shareholders
and has not provided the opportunity for remote presence through technical means (including the Internet), due to the
economic groundlessness of such a method of participation in the General Meeting.
The members of the Board of Directors attend the General Meetings of Shareholders of the company.
Materials for the General Meeting of Shareholders
The texts in the written materials related to the agenda of the General Meeting are specific and clear and do not mislead
the shareholders. All proposals regarding major corporate events are presented as separate items on the agenda of the
General Meeting, incl. the profit distribution proposal.
Due to technical reasons, the Company does not yet maintain a special section on its website regarding the rights of
shareholders and their participation in the General Meeting o f Shareholders, but the Board of Directors has undertaken
the necessary measures to do so.
The Board of Directors assists the shareholders entitled under the current legislation to include additional items and
to propose resolutions for items already inclu ded on the agenda of the General Meeting, by performing all necessary
legal and factual actions to announce the additional items added to the agenda of the already convened General
Meeting.
The Board of Directors ensures the right of the shareholders to be informed about the decisions taken by the General
Meeting of Shareholders by announcing the Minutes of the General Meeting of Shareholders through the selected
media agencies.
Equal treatment of shareholders of the same class
According to the Statute of the Company and the internal acts of the Company, all shareholders of the same class are
treated equally, and all shares within one class give equal rights to shareholders of the same class.

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The Board of Directors ensures that sufficient information is pr ovided to investors regarding the rights granted by all
shares of each class prior to their acquisition through the information published on the Company's website, as well as
through interviews and personal meetings with the management and/or the Director of Investor Relations.
Consultations between shareholders regarding their basic shareholder rights
The Board of Directors does not prevent shareholders, including institutional ones, from consulting each other on
matters relating to their basic shareholde r rights in a manner that prevents abuse.
Transactions of shareholders with controlling rights and abusive transactions
The Board of Directors does not allow transactions with shareholders with controlling rights, which violate the rights
and/or legitima te interests of other shareholders, including under the conditions of agreement with themselves.
Conducting this type of transactions requires an explicit decision of the Board of Directors and the interested parties
are excluded from the voting. In case o f indications for crossing the statutory thresholds under Art. 114, para. 1 of the
POSA, the Board of Directors prepares a motivated report and initiates the convening and holding of a General
Meeting of Shareholders, at which the transactions are put to a vote.
ІV. Chapter Four – Disclosure of financial and nonfinancial information
The Board of Directors has adopted a policy for disclosure of information in accordance with the legal requirements
and the bylaws of the Company. In accordance with the adopt ed policy, the corporate management has created and
maintains a system for disclosure of information.
The disclosure system ensures equality of the addressees of the information (shareholders, stakeholders, investment
community) and does not allow misuse o f inside information.
The inside information is disclosed in the legally established forms, order and terms through the selected media
agencies. The Company uses a single point to disclose information by electronic means, thus the information reaches
both the public and the FSC and the regulated securities market in an uncorrected form. Information in uncorrected
form and in the same volume is also published on the Company's website. In this way, the company's executive
management ensures that the disclosur e system provides complete, timely, accurate and understandable information
that allows for objective and informed decisions and assessments.
The Executive Management and the Board of Directors promptly disclose the capital structure of the Company and
agr eements that lead to exercising control in accordance with its disclosure rules. The disclosure is made through the
provisions of the Public Offering of Securities Act and the acts for its implementation, as well as the applicable
European regulation.
The Board of Directors ensures, by exercising control over the implementation of the disclosure policy, that the rules
and procedures according to which the acquisition of corporate control and extraordinary transactions such as mergers
and sale of significant parts of assets carried out are clearly and timely disclosed.

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The Board of Directors approves and together with the independent auditor controls internal rules for the preparation
of the annual and interim reports and the procedure for disclosure of information.
The Company maintains a website - www.allterco.com with approved content, scope and frequency of the information
disclosed through it. For technical reasons, the content of the Company's website does not fully cover the
recommendations of the National Corporate Governance Code, but the Board of Directors has undertaken appropriate
measures.
The Company also maintains an English language version of the corporate website with similar content.
The Company periodically discloses information about the corporate governance.
The Board of Directors of the Company believes that its activities in the reporting period created prerequisites for
sufficient transparency in its relations with investors, financial media and capital market analysts.
In the reporting period, the Company disclosed all regulated information w ithin the deadlines and in accordance with
the procedure provided for in the Public Offering of Securities Act and the acts on its implementation.
V. Chapter Five – Stakeholders. Sustainable development.
The corporate governance ensures effective interaction with the stakeholders. This category includes certain groups
of persons who are directly affected by the company and who in turn can influence its activities.
The Company identifies as stakeholders in relation to its activities the following groups of pers ons: employees,
creditors, suppliers and other contractors related to the implementation of the Company's activities.
The corporate management shall ensure that all stakeholders are sufficiently informed of their statutory rights. At the
end of the reporti ng period, Corporate Management had not developed specific policies to address stakeholder interests
but is committed to taking appropriate action to comply with this requirement in 2022.
In its policy regarding the stakeholders, Company complies with the legal requirements based on the principles of
transparency, accountability and business ethics.
The corporate management is committed to establishing specific actions and policies regarding the sustainability of
the company, including the disclosure of inf ormation related to climate and social aspects of their operations.
The corporate management maintains effective relations with stakeholders and is prepared to inform the company,
when necessary, in accordance with legal standards and good international pr actice for disclosure of non - financial
information, about economic, social and environmental issues of concern to stakeholders, such as: anti - corruption;
dealing with employees, suppliers and customers; the company's social responsibility; environmental pr otection and
human rights violations.
The corporate management ensures the right to timely and regular access to relevant, sufficient and reliable
information about the company when stakeholders are involved in the corporate governance process

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4. Descripti on of the main characteristics of the systems for internal control and risk management of
ALLTERCO JSCo in connection with the financial reporting process
When describing the main characteristics of the internal control and risk management systems, it shou ld be borne in
mind that neither the POSA nor the National Corporate Governance Code define an internal control framework for
public companies in Bulgaria to follow. Therefore, for the purposes of fulfilling the obligations of the Company under
Art. 100n, para. 8, item 4 of POSA, the description of the main characteristics of the systems uses the framework of
International Auditing Standard 315.
General description of the internal control and risk management system
The company employs a system for internal control and risk management (“the system”), which ensures the effective
functioning of the reporting and disclosure systems, as well as an Audit Committee. The system is also built and
operates in order to identify the risks associated with the Company's a ctivities and support their effective management.
The Board of Directors bears the main responsibility and has a role in establishing the system of internal control and
risk management. It performs both a management and guidance function as well as ongoing monitoring.
The ongoing monitoring by the corporate management consists of assessing whether the system is still appropriate in
a changed environment, whether it is operating as expected and whether it is periodically adapting to changed
conditions. The e valuation of selected areas, performed in this context as the responsibility of senior management, is
in line with the Company's priorities.
The Board of Directors monitors the main characteristics and features of the system, including the identified major
incidents and the corrective actions undertaken or implemented, respectively.
Control environment
The control environment includes the functions of general management, as well as the attitude, awareness and actions
of the corporate management.
• Commitment for competence. The Board of Directors of the company, as well as those involved in the
internal control and risk management process, have the relevant knowledge and skills necessary to perform
the tasks. The executive members of the Board of Di rectors of the Company monitor the levels of competence
required for the specific position and the ways in which those competences become necessary requisites for
skills and knowledge.
• Participation of persons involved with general management. The respons ibilities of the members of the
Board of Directors are stated in the Statutes of the Company and the management contracts. In addition, the
Executive Members of the Board of Directors are responsible for supervising the design of the model and the
effectiv e functioning of the warning procedures and processes of reviewing the effectiveness of the
Company's internal control.
• Philosophy and operational style of the management. The philosophy and operational style of the
management cover a wide range of characteristics. The attitudes of the members of the Board of Directors

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and their actions in relation to financial reporting are manifested through the choice of more conservativ e
accounting principles.
• Organizational structure Establishing an appropriate organizational structure involves defining an
appropriate number of hierarchical levels and defining the basic powers and responsibilities for each of these
levels. The Board of Directors assesses the appropriateness of the organizational structure of the Company,
taking into consideration the size and nature of the activities performed.
• Assignment of powers and responsibilities . When assigning powers and responsibilities to the employees
in the Company, the management shall take into account the applicable business practices, knowledge and
experience of employees and available resources available in the Company.
• Policies and practices related to human resources. When recruiting staff, the Executive members of Board
of Directors focus on qualifications, previous professional experience, past accomplishments, and evidence
of integrity and ethical conduct. The commitment of corporate management is to hire competent and reliable
empl oyees.
Risk assessment process in the Company
The process of risk assessment by the corporate management is the basis on which the Board of Directors of the
Company determines the risks to be managed.
The Board of Directors of the Company identifies the following types of risk that affect the Company and its activities:
general (systematic) and specific (non - systematic) risks.
Systematic risks are related to the macro environment in which the Company operates, which is why in most cases
they cannot be co ntrolled by the management team.
Non - systematic risks are directly related to the activities of the Company and depend mainly on corporate governance.
To minimize them, we rely on increasing the efficiency of internal company planning and forecasting, whic h provides
opportunities to overcome possible negative consequences of a risky event.
Each of the risks related to the country - political, economic, credit, inflation, foreign exchange, has its individual
significance, but the interaction between them for ms a comprehensive picture of the main economic indicators, market
and competitive conditions in the country in which each company operates.
A detailed description of the risks typical for the activity of ALLTERCO JSCo is presented in the section MAIN
RISK S, WHICH THE COMPANY FACES in this activity report.
Information system and related business processes essential for financial reporting and communication
The information system, essential for the purposes of financial reporting, which includes the accou nting system,
consists of procedures and documentation, developed and established for the purpose of: initiating, recording,
processing and reporting transactions and operations of the company and maintaining accountability; solving problems
with incorrect processing of transactions and operations and procedures, for timely correction; processing and

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reporting of cases of bypassing the systems or overcoming the controls; coverage of information essential for financial
reporting operations, such as depreciat ion of tangible and intangible assets and changes in the collectability of
receivables; and ensuring that the financial information required for disclosure is collected, processed, summarized
and appropriately reflected in the financial statements.
The Com pany's communication of the roles and responsibilities in the financial reports and important issues includes
the definition of individual roles and responsibilities related to internal control. It includes such matters as the extent
to which the accountin g team understands how its activities in the financial reporting information system relate to the
work of others and the means of reporting exceptions to the corporate governance.
The communication is carried out on the basis of financial reporting rules a greed with the registered auditor. Open
communication channels help ensure that exceptions are reported and acted upon.
Ongoing monitoring of controls
The ongoing monitoring of controls is a process for assessing the effectiveness of the internal control results over
time. It includes timely assessment of the effectiveness of controls and undertaking the necessary remedial actions.
The corporate management performs ongoing monitoring of the controls. Ongoing monitoring activities are often
embedded in the Company's day - to - day recurring activities and include regular managerial and supervisory activities.
5. Information under Article 10, paragraph 1, letters "c", "d", "f", "h" and "i" of Directive 2004/25/ЕC of the
European Parliament and of the Council of 2 1 April 2004 on takeover bids
5.1. Information under Article 10, paragraph 1, letters "c" of Directive 2004/25/ЕC of the European Parliament
and of the Council of 21 April 2004 on takeover bids - significant direct and indirect shareholdings (including
i ndirect shareholdings through pyramid structures and cross - shareholdings) within the meaning of Article 85
of Directive 2001/34/EC
At the end of the reporting period, the shareholders holding 5 percent or more of the capital and voting rights in the
General Meeting of the Company are:
Table 18
SHAREHOLDER PERCENTAGE OF THE CAPITAL
Svetlin Todorov 32.48%
Dimitar Dimitrov 32.48%
Other individuals and legal entities 35.04%
The Company has no other shareholders who directly or indirectly hold 5 percent or more than 5 percent of the voting
rights in the General Meeting.
5.2. Information under Article 10, paragraph 1, letters "d" of Directive 2004/25/ЕC of the European Parliament
and of the Council of 21 April 2004 on takeover bid s - the holders of any securities with special control rights
and a description of those rights

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ALLTERCO JSCo has no shareholders with special control rights .
5.3. Information under Article 10, paragraph 1, letters "f" of Directive 2004/25/ЕC of the European Parliament
and of the Council of 21 April 2004 on takeover bids - any restrictions on voting rights, such as limitations of
the voting rights of holders of a given percentage or number of votes, deadlines for exercising voting rights, or
systems whereby, with the company’s cooperation, the financial rights attaching to securities are separated
from the holding of securities
There are no restrictions on the vo ting rights of the shareholders of ALLTERCO JSCo. To participate in the General
Meeting, shareholders must identify themselves with the documents specified in the law, the Statute and the invitation
to the General Meeting, certifying their identity and rep resentative power and be registered by a mandate commission
in the list of attending shareholders prior to the starting time of the General Meeting.
5.4. Information under Article 10, paragraph 1, letters "h" of Directive 2004/25/ЕC of the European Parliam ent
and of the Council of 21 April 2004 on takeover bids - the rules governing the appointment and replacement of
board members and the amendment of the Articles of Association
Pursuant to the provisions of the Statute of the Company, the General Meeting o f Shareholders determines the number,
elects and dismisses the members of the Board of Directors and determines the remuneration for their work in it.
According to Art. 25, para. 1 of the Statutes of the Company, the term of office of the Board of Director s is determined
by the General Meeting, but it cannot be longer than 5 years.
The General Meeting of Shareholders may at any time decide to make changes in the number and composition of the
Board of Directors, and the members of the Board may be re - elected without restriction. The General Meeting of
Shareholders may at any time decide to make changes in the number and composition of the Board of Directors, and
members of the Board may be re - elected without restriction. A member of the Board of Directors may be any legally
capable individual and a legal entity that meets the requirements of the law and has the necessary professional
qualifications in connection with the Company's activities.
5.5. Information under Article 10, paragraph 1, letters "i" of Direc tive 2004/25/ЕC of the European Parliament
and of the Council of 21 April 2004 on takeover bids - the powers of board members, and in particular the
power to issue or buy back shares
The Board of Directors of ALLTERCO JSCo has the following powers:
The Boa rd of Directors discusses and resolves all issues other those that falling within the exclusive competence of
the General Meeting of Shareholders, including but not limited to:
(i) plans and programs for the Company's activities;
(ii) organizational structure of t he Company;
(iii) participation in tenders and competitions;
(iv) adopting and modifying the rules of procedure of the Board of Directors;

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(v) election and dismissal of the Executive Members in its staff;
(vi) acquisition of Company's participation in other companies;
(vii) opening and closing of branches of the Company in the country and abroad
(viii) acquisition and alienation of real property and limited real rights owned by the Company;
(ix) creating a mortgage on the Company's real estate or pledge on fixed tangible asse ts of the Company;
(x) granting loans to third parties, providing guarantees, taking out guarantees and providing collaterals for the
obligations of third non - related parties, concluding bank loan agreements for an amount (excluding interest
and charges) of ab ove 3% (three percent) of the value of the consolidated revenue of the Company, according
to the last audited annual financial statement of the Company;
(xi) the conclusion by the Company of operating or financial leasing contracts for amounts exceeding BGN
250 ,000 (excluding interest and charges);
(xii) disposal of intellectual property rights, including acquisition, sale and assignment of licenses for the use of
patents, know - how and other intellectual property rights (with the exception of intellectual property rig hts
granted to third parties in connection with the granting of products and services to end users within the scope
of the Company's purpose of business);
(xiii) determining the conditions for the appointment and adoption of programs for material incentives on an annual
basis for key management personnel of the Company's subsidiaries, namely, executive directors, procurators
and managing directors of the Company's subsidiaries.
to constitute and reconstitute the Advisory Board, to take decisions on all matters con cerning the Advisory Board,
except those previously determined by this Statute or by a decision of the General Meeting of Shareholders, including
but not limited to: to determine the number and personnel of the Advisory Board, to appoint and dismiss its me mbers
at its discretion, to determine the term of its existence, the remuneration and the mandate of its members, to adopt,
amend, revoke and monitor the implementation of any and all documents concerning the Advisory Board, including
the Rules on the func tioning of the Advisory Board.
The Board of Directors takes decisions regarding and authorizes the persons who manage and/or represent the
Company to conduct transactions with stakeholders within the meaning of Art. 114, para. 2 of POSA, for which no
prior authorization by the General Meeting of Shareholders is required.
With Decision of the General Meeting of Shareholders of 15.10.2021, the Board of Directors is authorized Up to five
years as of 27.06.2019, the Board of Directors is entitled to take decisi ons to increase the capital of the company,
under any of the methods provided for under para. 1 except for by converting part of the profit into capital, until
reaching a total nominal value of BGN 25,000,000 (twenty - five million) by issuing and public off ering of up to
10,000,000 (ten million) new dematerialized ordinary registered shares with the right of one vote, with a nominal
value of BGN 1 (one) each and an issue value of one share, determined by an express decision of the Board of Directors
of the C ompany. The restrictions set out here above shall apply in general regardless of which of the methods provided
for under para. 1 here above has been used for the capital increase.

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The company may buy back its own shares without making a trading offer, acq uiring in the course of one calendar
year no more than 3 per cent of its treasury voting shares, per decision of the General Meeting of Shareholders, for a
term not exceeding eighteen months from the date of the decision of the respective body of the Compa ny. The
Company may buy back its own shares by decision of the General Meeting of Shareholders for the purposes the
implementation of programs for additional material incentives for the employees within its group with the provision
of Company’s shares and the schemes for granting variable remuneration in shares to the executive members of the
Board of Directors, in accordance with the Remuneration policy of the members of the Board of Directors of the
Company.
6. Members and functioning of the administrativ e, management and supervisory bodies of ALLTERCO JSCo
and their committee
ALLTERCO JSCo has a one - tier management system. The Company is managed and represented by a Board of
Directors, which, as of the date of preparing this declaration has the following members, according to a decision of
the General Meeting of Shareholders of 21.09.2020:
• Dimitar Stoyanov Dimitrov;
• Svetlin Iliev Todorov;
• Nikolai Angelov Martinov
The Board of Directors of ALLTERCO JSCo elects a Chairperson and a Deputy Chairperson from its members. The
Board of Directors meets at regular meetings at least once in three months to discuss the state and development of the
Company. Each member of the Board may request the Chairperson to convene a meeting to discuss specific issues.
By resolution of the General Meeting of Shareholders dated 08.04.2022, amendments to the Company's Articles of
Association were adopted, according to which decisions of the Board of Directors shall be taken by a majority of more
than half of all members of the Board of Directors. A quorum at meetings of the Board of Directors is present if the
number of members present at the meeting is sufficient to make decisions on the items on the agenda. If a quorum is
not present on any of the items requiring a qualif ied majority, the lack of a quorum is noted in the minutes and this
item is not considered at the meeting.
The Board of Directors may take decisions in absentia.
Committees
The Company has an Audit Committee elected by the Annual General Meeting of Shareho lders composed of Anelia
Petkova Angelova - Tumbeva, Kamelia Vassileva Filipova, Albena Benkova Beneva. The Audit Committee performs
its functions in accordance with the Statute adopted by the Annual General Meeting of Shareholders and the
requirements of the Independent Financial Audit Act.
In compliance with the last amendments in the Statute of Company the Board of Directors has decided to establish
an Advisory Board in the Company and has appointed Mr. Gregor Bieler for its chairman. The Advisory Board is a

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collective advisory body, which assists the members of the Board of Directors and the senior management of the
Company, based on the expertise of each of its members and according to the goals set by the Board of Directors in
its constitution, as for this purpose it can (the enumeration is exemplary):
(i) to prepare and provide strategic guidelines and programs for development of the Company;
(ii) to monitor the activity and the results of the activity of the Company, to prepare reports and to give proposals
f or improvement of some aspects of the Company’s activity;
(iii) to provide information on the current developments and trends in the business sector in which the Company
operates;
(iv) to provide information on innovative practices, as well as to recommend and develo p programs for
introduction of such practices in the activities of the Company;
(v) to propose improvements regarding the products and / or services offered by the Company, as well as the
development of new ones;
(vi) to propose strategies for improving the Company 's position in the current markets in which it operates, to
explore opportunities for access to new markets, as well as for the implementation of new market mechanisms;
(vii) to perform any other activity assigned to it by the Board of Directors, which is in the interest of the
development of the Company.
The Advisory Board does not explicitly and cannot be assigned any management, controlling or supervisory functions.
The members of the Advisory Board have the right to access information belonging to the Company in the volume
determined by the Board of Directors and subject to the requirements for handling such information no less restrictive
than the requirements applicable to members of the Board of Directors.
7. Description of the diversity policy appl ied in relation to the administrative, management and supervisory
bodies of ALLTERCO JSCo in connection with aspects such as age, gender or education and professional
experience, the objectives of this diversity policy, the manner of its implementation and results in the reporting
period; where no such policy is applied, the declaration contains an explanation of the reasons for this.
The company has not developed a special diversity policy with regard to the administrative, management and
supervisory bodie s of the company in relation to aspects such as age, gender or education and professional experience,
as it falls within the exceptions of Art. 100n, para. 12 of the POSA.
However, there are long - established practices that can be classified as a diversity policy with regard to the governing
bodies regarding aspects such as age, gender or education and professional experience.
In essence, these practices form the Company's diversity policy of the management bodies in relation to aspects such
as age , gender or education and professional experience, the objectives of this diversity policy.
The adopted practices require the Company to apply a balanced policy for nominating members of the corporate

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management who have education and qualifications that c orrespond to the nature of the company's work, its long -
term goals and business plan.
The adopted practices of the Company encourage the pursuit for gender balance at all management levels.
The Company does not discriminate against members of corporate man agement on the basis of age.
...................................................................
Dimitar Dimitrov
Executive Director of ALLTERCO JSCo

Page 117 of 117
DECLARATION
under Article 100n(4)(4) of the Public Offering of Securities Act
We, the undersigned,
DIMITAR STOYANOV DIMITROV, in my capacity as Chief Executive Director of ALLTERCO JSCo, UIC:
201047670, registered office and address of management: Sofia, 103 Cherni Vrah Blvd. (“the Issuer”) and
SVETOZAR GOSPODINOV ILIEV, in my cap acity as Chief Financial Officer of ALLTERCO JSCo and preparer of
the annual financial report for 2021 of this company on a consolidated basis in accordance with Art. 100n(o), para. 4
of the Public Offering of Securities Act (POSA)
Hereby DECLARE that t o the best of our knowledge:
1. The consolidated annual financial statements of the company for 2021, prepared in accordance with the applicable
accounting standards, present correctly and fairly the information about the issuer's assets and liabilities, fina ncial
standing and profit or loss and of the companies included in the consolidation;
2. The Report on the Business Activities contains a truthful review of the development and results from the activity
of the Issuer, as well as the condition of the Issuer, t ogether with a description of major risks and uncertainties
faced thereby.
Declarers:
...................................
Dimitar Dimitrov
Chief Executive Director of Allterco JSCo
......................................
Svetozar Iliev
Chief Financial Officer