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PAL Holdings, Inc.PAL

PSE Disclosure Form 17-12-A - List of Top 100 Stockholders (Common Shares) Reference: Section 17.12 of the Revised Disclosure Rules

Type of Securities

Common

For the period ended	Dec 31, 2025

Description of the Disclosure
We are submitting herewith the List of Top 100 Stockholders (Common Shares) of the Company as of December 31, 2025. According to the report from our Stock and Transfer Agent, there is a discrepancy of 9,634,261 common shares common shares between the cumulative certificated common shares and lodged shares compared to the total issued and outstanding shares reported in the PHI month-end report. This difference primarily reflects the common shares pending issuance of their CAR (Certificate Authorizing Registration) from the BIR. To provide context, between 2017 and 2018, PAL and PHI executed a share swap transaction allowing PAL shareholders to exit through the stock exchange. While some shareholders have received their CARs, the issuance of 9,634,261 shares is pending, and therefore their status cannot currently be reflected in certificated or lodged shares. Additionally, please note that the 15,241,128,648 shares are not yet included in certificated shares as we have not issued stock certificates for them. They are also not lodged with the PCD (Philippine Central Depository) as they have not yet been listed. We can only lodge them with the PCD once they are officially listed. Furthermore, 532,507,500 shares, which form part of the Corporation’s outstanding capital stock, remain unpaid and are neither lodged nor certificated. These shares were subscribed through private placement under terms providing that the balance of the subscription price shall be payable upon call by the Board of Directors. To date, the Board of Directors has not issued any call for the payment of the balance on these shares. We trust you will take note accordingly. Thank you.

Description of the Disclosure

We are submitting herewith the List of Top 100 Stockholders (Common Shares) of the Company as of December 31, 2025.

According to the report from our Stock and Transfer Agent, there is a discrepancy of 9,634,261 common shares common shares between the cumulative certificated common shares and lodged shares compared to the total issued and outstanding shares reported in the PHI month-end report. This difference primarily reflects the common shares pending issuance of their CAR (Certificate Authorizing Registration) from the BIR.

To provide context, between 2017 and 2018, PAL and PHI executed a share swap transaction allowing PAL shareholders to exit through the stock exchange. While some shareholders have received their CARs, the issuance of 9,634,261 shares is pending, and therefore their status cannot currently be reflected in certificated or lodged shares.

Additionally, please note that the 15,241,128,648 shares are not yet included in certificated shares as we have not issued stock certificates for them. They are also not lodged with the PCD (Philippine Central Depository) as they have not yet been listed. We can only lodge them with the PCD once they are officially listed.

Furthermore, 532,507,500 shares, which form part of the Corporation’s outstanding capital stock, remain unpaid and are neither lodged nor certificated. These shares were subscribed through private placement under terms providing that the balance of the subscription price shall be payable upon call by the Board of Directors. To date, the Board of Directors has not issued any call for the payment of the balance on these shares.

We trust you will take note accordingly. Thank you.

Number of Issued Common Shares	26,852,131,905
Number of Treasury Common Shares, if any	25,015
Number of Outstanding Common Shares	26,852,106,890
Number of Listed Common Shares	25,755,747,644
Number of Lodged Common Shares	6,201,312,492
PCD Nominee - Filipino	364,996,690
PCD Nominee - Non-Filipino	5,836,315,802
Number of Certificated Common Shares	20,641,185,152

Change from previous submission
In contrast to the previous report, which reflected the entire 1,086,750,000 shares as unpaid, 554,242,500 shares have since been fully paid. The remaining 532,507,500 shares remain unpaid and are neither lodged nor certificated.

Filed on behalf by:

Name	Ma. Cecilia Pesayco
Designation	Corporate Secretary