Shareholder Engagement Policy

Last updated and adopted: 21 October 2026

1. Purpose and scope

Pursuant to § 4-7 of the Norwegian AIF Law (“the AIFM Act”) and § 3-6 of the Norwegian AIFM Regulation (“the AIFM Regulation”), alternative investment fund Managers (“AIFM”) are required to publish procedures describing their shareholder engagement in relation to their investment in shares admitted to trading on a regulated market situated or operating in the EEA.

Highvern AIFM Services AS (“Highvern AIFM”) as an AIFM primarily manages funds investing in unlisted assets. Such investments do not fall within the scope of the shareholder engagement requirements referred to above.

2. Delegated portfolio management and shareholder engagement

Highvern AIFM also acts as AIFM to certain alternative investment funds which may invest in shares falling within the scope of § 4-7 of the AIFM Act.

For such funds, Highvern AIFM does not itself perform portfolio management or shareholder engagement activities. The portfolio management function including shareholder engagement, is delegated to licensed third-party managers (“Third-Party Managers”).

Accordingly, the obligations following from the AIFM Act § 4-7 and AIFM Regulation § 3-6, such as the integration of active ownership into the investment strategy, monitoring of investee companies, dialogue with investee companies, the exercise of voting and other shareholder rights, cooperation and communication with other shareholders and relevant stakeholders, and the management of conflicts of interest relating to shareholder engagement, is carried out by the relevant Third-Party Manager in accordance with its applicable shareholder engagement policy.

As part of its oversight responsibilities, Highvern AIFM is responsible for keeping up to date with legislative changes and will ensure that:

• Shareholder engagement disclosure requirements in accordance with the AIFM Act are made publicly available by Third-Party Managers; and
• Third-Party Managers’ shareholder engagement policies are abided by.

As of the date of this policy, the relevant delegated portfolio managers consist of:

Hausta Kapitalforvaltning AS, in respect of Hausta Investor AS.