The administrative fine order is final and binding.

Update (5 September 2024):

On 27 August 2024, the company lodged an appeal against the administrative fine order.

Background information: voting rights notification requirements

Shareholders are required to submit a notification to BaFin and the issuer whenever their shares of voting rights reach certain thresholds. The notification must be submitted within four trading days.

As stipulated in section 12 (1) of the German Securities Trading Reporting Regulation (Wertpapierhandelsanzeigeverordnung – WpAV), shareholders are required to use a binding voting rights form to submit the notification.

Any party subject to the notification requirement that fails to notify BaFin and the issuer within the prescribed period in the event that their share of voting rights exceeds or falls below certain thresholds is in violation of section 33 (1) sentence 1 of the WpHG. BaFin may sanction such violations by imposing a fine. For legal persons, this fine may amount to a maximum of EUR 10 million or up to 5% of the company’s total turnover.

The requirement to submit voting rights notifications serves to enhance transparency on the capital market. It is intended to make Germany as a financial centre more attractive and to strengthen investor trust in the functioning of the German stock market.