Reporting Office Rules
(RR)

2.1 Trade Report

Participants admitted to SIX Swiss Exchange AG must submit Trade Reports as follows: ‒ On-exchange, off-order-book trades in accordance with the SIX Swiss Exchange AG Trading Rules, or ‒ Trades outside of SIX Swiss Exchange AG ("off-exchange trades") in accordance with the Reporting Office Rules. Reportable off-exchange trades on SIX Swiss Exchange AG in securities admitted to trading at a Swiss trading venue must be reported to the Reporting Office using a Trade Report. Paragraphs 3 and 4 remain reserved. Trade Reports are not required to be submitted to the Reporting Office for reportable trades in securities admitted to trading at a Swiss trading venue at foreign trading venues or foreign organised trading facility (OTF) if the trade has already been reported to the competent foreign authority in the form of a Trade Report and published by that authority. Foreign branches of Swiss securities firms may fulfil their obligation to submit Trade Reports for trades executed abroad via a foreign reporting office recognised by SIX Swiss Exchange AG. Information from the Trade Report will be published to fulfil SIX Swiss Exchange AG post-trade transparency requirements.

In the Reporting Rules, the term “securities” also includes derivatives.

2.2 Content of Trade Reports

Trade Reports must contain the following information as a minimum: a) Identification of the party subject to the duty to report; b) Transaction type (buy or sell); c) Precise identification of the securities or derivatives in question (attributes such as the ISIN); d) Execution volume (depending on the security a nominal value, number of units or contracts); e) Execution price or price obtained on the market excluding commission and fees (incl. statement of currency); f) Time of execution (date and time); g) Information on whether the trade was a proprietary transaction (trading in own name and for own account) or a client transaction (transaction in own name but for the account of the client); h) Designation of the counterparty; i) Designation of the trading venue where the securities or derivative were traded, or the notification that the transaction was executed outside a trading venue; j) Trade Type: designation which further specifies the report (Annex A).

2.3 Transaction Report

For reportable trades in Swiss securities admitted for trading at a Swiss trading venue, a Transaction Report must be submitted to the Reporting Office. Furthermore, this shall also apply to trades in foreign securities admitted for trading at a Swiss trading venue, ‒ provided the trade is conducted at a Swiss trading venue or ‒ outside a foreign trading venue recognised by FINMA.2 Clause 2.3, paragraph 1 (preceding) also applies to reportable trades in derivatives derived from securities admitted for trading at a Swiss trading venue. Every Transmission of Orders for securities admitted to trading at a Swiss trading venue or for derivatives derived from securities admitted for trading at a Swiss trading venue which ultimately results in a trade must be reported by Transaction Report to the Reporting Office by every party in the transaction chain which is subject to the duty to report. The Transaction Report serves to fulfil regulatory requirements and is not published.

2.4 Content of Transaction Reports

Transaction Reports in the Swiss format must contain the following information as a minimum: a) Identification of the party subject to the duty to report; b) Transaction type (buy or sell); c) Precise identification of the securities or derivatives in question (attributes such as the ISIN or CFI); and additionally in the case of derivatives the name of the underlyings and further determining characteristics of the derivative, namely the classification of the derivative; d) Execution volume (depending on the security a nominal value, number of units or contracts); e) Execution price or price obtained on the market excluding commission and fees (incl. statement of currency); and additionally in the case of derivatives, the further value-determining parameters, depending on the classification of the derivative, namely:

The exception outlined in Annex A Clause 1 Reporting Rules shall remain unaffected.

1. whether it is a call or put option, 2. the strike price, 3. the price multiplier and 4. the term of the contract or the expiry date; f) Time of execution or time of order fulfilment in the case of Transmissions of Orders (date and time); g) Information on whether the trade was a proprietary transaction (trading in own name and for own account) or a client transaction (transaction in own name but for the account of the client); h) Designation of the counterparty or, in the case of Transmissions of Orders: designation of the party to whom the order was transmitted; i) Designation of the trading venue where the securities or derivative were traded, or the notification that the transaction was executed outside a trading venue; j) Information permitting the beneficial owner to be identified, or in the case of Transmissions of Orders: the designation of the party who transmitted the order; k) Transaction identification code (trade ID). The format of the Transaction Report must comply in full with either the Swiss format, as defined in FINMA Circular 2018/2, or with RTS 22 (governed by Clause 2.7.2 below). An indication of the transaction identification code (Trade ID) forms part of a complete report in accordance with the Swiss format or RTS 22 (governed by Clause 2.7.2 below). As an exception to margin number 13 of FINMA Circular 2018/2, FINMA grants an exemption from the requirement to include the transaction identification code (Trade ID) in Transaction Reports relating to trades executed on foreign trading venues, provided that the order is routed via a third-party broker.

2.5 Registration

Those subject to the duty to report must be registered with the Reporting Office before they are able to submit reports. They will receive a registration number. Participants of SIX Swiss Exchange AG are deemed registered.

2.6 Reporting deadlines

During trading hours, Trade Reports must be submitted to the Reporting Office within the following deadlines after the trade has been effected: a) One minute for equities, global depository receipts, rights and options; b) Three minutes for investment funds, Exchange Traded Funds (ETF), Exchange Traded Structured Funds (ETSF), Exchange Traded Products (ETP), Sponsored Funds and Structured Products; c) 15 minutes for bonds. Trade reports for trades in equities and global depository receipts carried out in connection with a delta-neutral hedge with respect to a derivative transaction must be reported within five minutes at the latest. The trades are to be flagged with the trade type “Derivative Hedge” (Annex A). VWAP (Volume Weighted Average Price) trades must be reported with the actual VWAP achieved and using the “Special Price” Trade Type (Annex A) no later than 30 minutes after the close of trading if the trade is an off-order-book fixed price transaction. Trades at a future net asset value are deemed to be effected in accordance with paragraph 1 as soon as the net asset value on which the trade is based is known. The trades are to be reported with the trade type “NAV Trade” (Annex A).

Trade Reports for trades outside of SIX Swiss Exchange AG trading hours must be submitted before the start of trading on the trading day following the trade at the latest. Transaction Reports must be submitted by close of trading on the next trading day at the latest.

2.7 Reporting functions

2.8 Correction, cancellation of reports and countertrades

3.1 Information published from Trade Reports

The price, volume and time of the trade are published immediately when a Trade Report is submitted.

3.2 Delayed publication of Trade Reports

Trades in equity securities and illiquid bonds, or large in scale bond trades, may be published with a delay at the request of the party subject to the duty to report. The provisions on delayed publication pursuant to Annex B of these Rules otherwise apply.

5.1 Emergency situations

Those subject to the duty to report must immediately notify the Reporting Office in the event of an emergency situation (failure of the reporting or access system, force majeure). Emergency situations do not, as a rule, constitute a release from the duty to report. Trade Reports following emergency situations must be marked additionally with the "Special Price" Trade Type.

5.2 Inspection right

The Reporting Office has the right at all times to inspect compliance with legal and regulatory provisions, or to have it inspected. Those subject to the duty to report undertake to permit the office conducting the inspection to inspect all documents and provide such information as is necessary to carry out the inspection. The Reporting Office may invoice those subject to the duty to report for the costs associated with the inspection. The Reporting Office may inform or involve FINMA.

5.3 Confidentiality

The Reporting Office, its governing bodies, staff and agents are subject to professional secrecy pursuant to Art. 147 FinMIA. Notwithstanding statutory provisions to the contrary or rules to the contrary set out in these Reporting Rules, the Reporting Office shall treat as confidential all information which is subject to reporting obligations that it receives in connection with the Reporting Rules. The Reporting Office shall only publish such confidential information, with the exception of that set out in Clauses 3.1 and 3.2, with the consent of the participants concerned. The Reporting Office may disclose data to SIX Group AG companies and/or its staff in Switzerland and abroad, provided the Reporting Office ensures that the group company concerned and/or the staff concerned are bound by confidentiality provisions that are comparable to those of these Reporting Rules. This applies in particular in the context of internal group activities involving more than one company

and/or country, e.g. concerning product developments/improvements, market analyses, marketing, optimisation of customer services and risk management, and to facilitate organisation within the group. The Reporting Office may disclose data to external third parties in Switzerland and abroad necessary for the performance of their contractual duties (in particular central counterparties and settlement organisations), provided the Reporting Office ensures that these parties are bound by confidentiality provisions that are comparable to those of these Reporting Rules. The Reporting Office is authorised to outsource data processing and other services to third parties in Switzerland and abroad, in particular to group companies of SIX Group AG. This concerns, in particular, liquidity management, treasury, risk management, internal auditing, the management of core data, data retention or storage, accounting, personnel, IT and back-office functions, legal and compliance, activities designed to guarantee fair, efficient and orderly trading, and the operating of matching, market and reference data distribution systems. Where data is transmitted to group companies or external third parties as part of an outsourcing arrangement, all service providers will be subject to comprehensive confidentiality provisions.

5.4 Amendments to the Rules

Subject to the approval of FINMA, the Reporting Office may amend the Rules. Those subject to the duty to report will be notified of any amendments on the SIX Swiss Exchange AG website before they come into effect.

5.5 Applicable law and place of jurisdiction

The Rules are subject to Swiss law. The place of jurisdiction is Zurich, Switzerland. The Reporting Office Rules are available in German, French and English. The German version alone of the Reporting Office Rules is binding in the event of inconsistencies between the German, French and English versions.

5.6 Entry into force

The Reporting Office Rules issued on 19 May 2026 by the Management Committee of SIX Exchange Regulation AG and approved by FINMA on 20 April 2026 enter into force on 1 July 2026 and replace the Reporting Office Rules dated 12 May 2025.

Annex A – General Supplements

2.1 Illiquid securities

The participant may apply for delayed publication if all of the following provisions are fulfilled: a) the trade is executed off-order-book; and b) there is no liquid market for the security. There is deemed to be no liquid market for a security if one or more of the following criteria is/are not met: Average nominal value of trades per trading day during a < CHF 100,000 or the equivalent amount for securicalendar year ties with a foreign nominal currency. Average number of trades per trading day during a calendar < 15 year Average number of trading days on which traded during a < 80% calendar year Issue size during a calendar year a) for government bonds < CHF 1 billion or the equivalent amount for securities with a foreign nominal currency; or b) for other bonds < CHF 500 million or the equivalent amount for securities with a foreign nominal currency.

In the case of newly issued securities for which no data exists for the past three months, there is deemed to be no liquid market if the size of the government bond issue is less than CHF 1 billion and the issue size for other bonds is less than CHF 500 million (or the equivalent amount for securities with a foreign nominal currency). The Exchange publishes the authoritative liquidity data per security, with the static data.

2.2 Liquid securities