Atlas Special Opportunities, LLC

Revierstredet 3 P.O. Box 1187 Sentrum NO-0107 Oslo Tel. +47 22 93 98 00 post@finanstilsynet.no finanstilsynet.no Enquiries to [navn] Dir. line. +47 22 93 99 89 Atlas Special Opportunities, LLC c/o Arena Investors LP 405 Lexington Avenue, 59th Floor NEW YORK NY 10174 USA Our reference 25/13822 Your reference 13.08.2026 Decision on violation penalty Reference is made to the previous correspondence, including reply received from Arena Investors, LP (Arena) on behalf of Atlas Special Opportunities, LLC (Atlas) in a letter dated 26 March 2026 and in email dated 13 April 2026. The Financial Supervisory Authority of Norway (Finanstilsynet) further refers to its advanced notification of violation penalty in a letter dated 19 June 2026. Finanstilsynet has not received any comments regarding the advanced notification within the provided deadline which expired on 7 July 2026. Atlas exercised the conversion right under a debt instrument on 17 October 2025. As a result of the conversion, Atlas received shares in Circio Holding ASA (CRNA) and exceeded the 15 % disclosure threshold. The exceeded threshold was initially disclosed to the market on 30 October 2025 at 08:04 CET followed by correction notifications submitted on 30 October 2025 at 11:02 CET and on 3 November 2025 at 08:13 CET. Based on the information available, Finanstilsynet has concluded that Atlas' notification to the market was incomplete and submitted too late, and therefore in breach of section 4-2 cf. section 4-7 of the Norwegian Securities Trading Act (NSTA) and section 4-1 of the Norwegian Securities Trading Regulations (NSTR).