COMMITTEE'S DESCISION ON Q VARA


On May 6, 2008, the Listing and Surveillance Committee of the Tallinn Stock
Exchange reviewed the circumstances and materials collected in the course of
supervisory proceedings carried out with respect to AS Q Vara (hereinafter: Q
Vara) and decided to impose a fine in the amount of 50 000 kroons to Q Vara for
violation of TSE Rules. 


Circumstances: 

1. Q Vara disclosed its year 2007 unaudited financial statements on May 6,
2008, i.e. 6 days later than after 4 months has passed from the end of the
reporting period (2007 financial year). Q Vara has not disclosed the audited
financial statements for the year 2007 by the decision. 

2. In its letter to the Exchange from May 6, 2008, Q Vara explained the report
was ready on March 27, 2008 but since Q Vara sold its Latvian real estate on
March 28, 2008 (Jonathan's real estate project), that had significant effect on
the report and according to the IFRS it is obligatory to take such transactions
into account in the next period's report and as a request of the auditors the
audit process was started once again due to the selling of the Jonathan's real
estate project. In its e-mail form April 29, 2008 a representative of Q Vara
also explained the delay of the audited report with the need of revision of the
reports by the Polish auditors. 

3. Q Vara disclosed its 2007 financial year 12 months interim report on March
14, 2008. i.e. 14 days after the deadline stated in the Requirements for
Issuers (hereinafter RI) clause 5.4.5., giving an advance notification in a
stock exchange announcement on February 29, 2008. 

4. Q Vara justified the delay of the intermediary report with Silukaln real
estate project, other real estate investments and inventory value changes and
the lack of the auditors' final feedback. In addition, a reason for violation
of the rules was the resignation of an accountant of the Latvian subsidiary and
implementation of new accounting software. 

5. On January 2, 2008, Q Vara disclosed a stock exchange announcement about the
interest payment on January 2, 2008. According to the announcement, the list of
investors entitled to receive the interest was closed on January 7, 2008, i.e.
three exchange days after the disclosure of the announcement. Information
should have been published on December 18, 2007. Q Vara delayed in disclosing
information for 6 exchange days. 

6. The exchange has informed Q Vara of the supervisory proceedings and sending
the materials for review to the Listing and Surveillance Committee. 

Considering the materials submitted, the Committee concluded: 

1. Q Vara did not follow properly the information evaluation and disclosure
obligation in publication of the audited financial statements for the year
2007, the interim report for the 12 months of year 2007 and fixing the list of
the Q Vara has breached obligations set in RI, that oblige the issuer to
disclose its audited financial results at least four months and interim report
two months after the end of the accounting period. Q Vara has also breached the
requirements of notification of the closing date for the security holder list. 

2. Violation of the rules has been evidenced, as assessed by the Committee, by
the circumstances identified in the course of the supervisory proceedings
carried out by the TSE. 

3. There are no objective circumstances that would have prevented Q Vara to
follow the obligations properly. There are sufficient grounds for legal
protection measures within the competence of the TSE. 

4. Proceeding from the above the Committee concluded that Q Vara's activities
have been in conflict with RI clauses 1.2.1, 5.3.1, 3.6.2, 8.3.3, 5.4.5 and
2.4.1. 


Background:

According to clause 1.2.1. of RI, the Issuer is obliged to secure the
disclosure of the information specified in RI in such a form and within such
time limits as specified herein. 

According to clause 5.3.1. of RI, is an Issuer required to make public the
audited annual report immediately after its approval by the supervisory board
but not later than four (4) months after the end of the accounting period. 

According to clause 5.4.2.of RI, shall an issuer of debt securities publish
semi-annual interim reports on their operations and financial results for 6
months and 12 months of the financial year (preliminary annual accounts),
consisting also data of relevant half-year. 

According to clause 5.4.5. of RI, the Issuer is obliged to make public an
interim report immediately after its preparation by the management board, but
no later than two (2) months after the end of the reporting period. 

According to clauses 8.3.3. and 3.6.2. of RI, is an Issuer required to disclose
information about closing the list of holders of securities at least 9 (nine)
trading days before of the record date. 

According to clause 2.4.1. of RI, information is deemed disclosed when made
public as a notice through the Exchange information system. 


Tallinn Stock Exchange 
Market Services 
+372 6408800