Ryanair Holdings plc Loss Form

(a) the Company had experienced a breakdown in relations with its employees amidst their growing dissatisfaction with working conditions, lack of benefits, exploitative contracts and management hostility; (b) the Company’s pilots and/or cabin crews had sought union recognition or collectivization in several key markets and employees had internally expressed widespread discontent with the Company’s collective bargaining units; (c) the Company was experiencing elevated and increasing employee turnover, which had resulted in the loss of hundreds of qualified and skilled employees to competitor airlines; (d) the Company’s newly negotiated contracts had not ameliorated employee discontent or “locked away” employee wage growth for three or four years, but rather, defendants were aware that pilot and cabin crew contracts had to be reformulated to significantly increase pay and benefits, comply with local labor laws and provide other worker concessions to enable Ryanair to hire and retain sufficient qualified employees to meet operational targets; (e) because of the aforementioned, the Company was unable to hire sufficient pilots to meet expected demand and was thereby exposed to increased risk of flight cancellations, loss of reputational assets and increased costs from flight disruptions; (f) because of the aforementioned, the Company’s historical operating model and profit growth were not sustainable; and (g) the Company could not meet internal earnings expectations.