Date: 30th October 2018

We are alarmed that for the second time in less than two years the Republic of Slovenia moves to curtail the options available to minority shareholders to mitigate the burden of costs imposed on them by financial intermediaries. Specifically, the proposed Paragraph 10 of Article 296 of the Market in Financial Instruments Act (ZTFI-1) targets the “Share SUPPORT” scheme of the Pan-Slovenian Shareholders Association (VZMD) by limiting the duration of fiduciary securities accounts of dedicated attorneys used by the “Share SUPPORT” scheme to 12 months. We assess that such additional restrictions will seriously jeopardise the prospects of minority shareholders in the Slovenian capital market.