OPINION OF THE SUPERVISORY BOARD OF AKTSIASELTS EKSPRESS GRUPP IN RESPECT OF TAKEOVER BID

The  opinion of the  Supervisory Board of  Aktsiaselts Ekspress Grupp ("Ekspress
Grupp") ("Supervisory Board") has been drawn up on 9 December 2025 in accordance
with  § 171 (2) of the Securities Market  Act ("SMA") and § 21 of Regulation No.
71 of  the Minister of  Finance, dated 28 May  2002, "Rules for Takeover Offers"
("Rules")  with regard to the  voluntary takeover bid made  by HHL Rühm Osaühing
("Bidder") on 25 November 2025 for the acquisition of all the shares of Ekspress
Grupp not already owned by the Bidder ("Bid").

The  members of  the Supervisory  Board of  Ekspress Grupp  and the  persons who
prepared  this opinion are Ülar Maapalu (the Chairman of the Supervisory Board),
Argo Virkebau and Sami Jussi Petteri Seppänen.

Pursuant  to §  21 (2) 4) of  the Rules,  the Supervisory  Board shall  give its
assessment  on the impact of the takeover bid on the interests of Ekspress Grupp
as   the   target  issuer  and  its  employment  relationships  with  employees.
Independent  members of the Supervisory Board who are part of the composition of
the  Supervisory Board for the  purposes of § 21 (2)  4) of the Rules shall also
give  their assessment on the impact of the takeover bid on the interests of the
target issuer and its employment relationships with employees.

For  the purposes of  § 21 of the  Rules, independent member  of the Supervisory
Board is Sami Jussi Petteri Seppänen.

 1. Contracts of the members of the Supervisory Board and Management Board of
    Ekspress Grupp or other relations with the Bidder

The member of the Supervisory Board Ülar Maapalu has acted as the representative
and is the contact person of the Bidder in relation to the Bid.

The  members of the Management Board  of Ekspress Grupp ("Management Board") and
Supervisory Board have not concluded any contracts with the Bidder.

 1. Election of the Supervisory Board and Management Board

The  Supervisory Board members are elected by the shareholders of Ekspress Grupp
pursuant  to the  Articles of  Association of  Ekspress Grupp. No shareholder of
Ekspress Grupp has a special right to designate members of the Supervisory Board
or nominate members of the Supervisory Board.

The  Management Board members  are elected by  the Supervisory Board pursuant to
the Articles of Association of Ekspress Grupp.

 1. Conflicts of interest of the members of the Supervisory Board and the
    Management Board and measures to mitigate the risks

To  the  knowledge  of  the  Supervisory  Board,  none  of  the  members  of the
Supervisory  Board and  Management Board  have a  right to any compensation that
would  depend on  the Bid  or the  results thereof  and that  could result  in a
conflict of interest of the members of the Management Board or Supervisory Board
in relation to the Bid.

Since   the   member  of  Supervisory  Board  Ülar  Maapalu  has  acted  as  the
representative  and is the contact person of  the Bidder in relation to the Bid,
there is a risk of conflict of interests, despite the lack of compensation, in a
situation  where the Supervisory Board needs  to adopt resolutions regarding the
Bid.  Whereas, notwithstanding the submission of this opinion of the Supervisory
Board  (which the Supervisory Board  has submitted unanimously), the Supervisory
Board  has  not  adopted  any  resolutions  with  regard to the Bid and does not
foresee the need to adopt any resolutions with regard to the Bid.

Should  it  become  apparent  that  the  Supervisory  Board  needs  to adopt any
resolution  regarding the  Bid other  than this  opinion, the  Supervisory Board
shall  analyse the risk of  possible conflict of interest  of the members of the
Supervisory Board. In case a conflict of interest exists, the members who have a
conflict  of interest would refrain from voting  on the adoption of the relevant
resolutions of the Supervisory Board.

 1. Assessment on the impact of the Bid

All of the members of the Supervisory Board are on the opinion that the Bid does
not  have an  adverse effect  on Ekspress  Grupp nor  the interests  of Ekspress
Grupp.  The Bid and the  expected withdrawal from trading  on the stock exchange
are in line with Ekspress Grupp's long term strategic interests.

Implementation   of  the  company's  strategy  requires  qualified  work  force,
therefore  retaining and training the employees  is in the interests of Ekspress
Grupp.  Thus, no immediate and direct impacts  can be foreseen to the employment
relationships  of Ekspress Grupp's employees. However,  changes can not be ruled
out,  including  impact  to  employment  relationships  regarding  the review of
Ekspress Grupp's primary operations to continue to ensure the provision of high-
quality media.

The independent member of the Supervisory Board, Sami Jussi Petteri Seppänen, is
on the same opinion as the other members of the Supervisory Board.

 1. Intention of the members of the Supervisory Board and Management Board to
    accept the Bid

The  Chairman of  the Management  Board Mari-Liis  Rüütsalu will resign from the
Management  Board as of 31 December 2025 and will be replaced by a new member of
the Management Board Liina Liiv, who took office on 1 December 2025.

The Chairman of the Management Board, Mari-Liis Rüütsalu, owns in total 113,984
shares of Ekspress Grupp that belong to her indirectly through OÜ Norg, which is
under her control, and to the knowledge of the Supervisory Board, she intends to
accept  the  Bid,  if  there  are  no  restrictions  for  trading  arising  from
regulations or internal rules.

The  Chairman  of  the  Supervisory  Board,  Ülar Maapalu, owns 30,000 shares of
Ekspress Grupp that belong to him indirectly through OÜ Rumeelia, which is under
his  control, and he intends to accept the Bid, if there are no restrictions for
trading arising from regulations or internal rules.

The rest of the members of the Supervisory Board and the Management Board do not
own any shares of Ekspress Grupp, therefore they can not accept the Bid.

 1. Contracts of the members of the Supervisory Board and Management Board

There  are no  contracts between  Ekspress Grupp  and members of the Supervisory
Board  and  the  Management  Board  that  would  provide  for the termination of
agreement or payment of compensation to the members of the Supervisory Board and
Management  Board of Ekspress Grupp or a  third party in connection with the Bid
or the results thereof.

Ülar Maapalu
Chairman of the Supervisory Board
[email protected] (mailto:[email protected])

AS Ekspress Grupp is the leading Baltic media group whose key activities include
web media content production, and publishing of newspapers, magazines and books.
The Group also operates an electronic ticket sales platform and ticket sales
offices in Latvia and Estonia, offers digital outdoor screen service in Estonia
and Latvia. In addition, the Group companies organize conferences, trainings and
events mainly in Estonia and Lithuania but also in Latvia. Ekspress Grupp
launched its operations in 1989 and employs about 1000 people.