Capricorp Investments B.V.

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 Capricorp Investments B.V. Barbara Strozzilaan 101 1083 HN Amsterdam THE NETHERLANDS Our reference 26/2528 Your reference 09.06.2026 This letter is sent solely by email to bosman@invacomanagement.com. Decision on violation penalty Reference is made to the letter from the Financial Supervisory Authority of Norway (Finanstilsynet) dated 15 May 2026, and the reply received from Capricorp Investments B.V (Capricorp) dated 18 May 2026. Capricorp acquired shares in Soiltec ASA (STECH) on 16 January 2026. As a result of the transaction, Capricorp exceeded the 5 % disclosure threshold. The exceeded threshold was disclosed to the market on 17 February 2026. Based on the information available, Finanstilsynet has concluded that Capricorp notified the market too late and violated the Norwegian Securities Trading Act (NSTA) section 4-2. Finanstilsynet has therefore decided to impose a violation penalty of NOK 100,000 on Capricorp, cf. NSTA section 21-3. 1 Legal basis Pursuant to the NSTA section 4-2, a shareholder shall notify the issuer and the regulated market of a transaction which causes the shareholder`s proportion of shares reach, exceed or fall below 5 %, 10 %, 15 %, 20 %, 25 %, 1/3, 50 %, 2/3, or 90 % of the votes in a company whose shares are quoted on a regulated market. The NSTA section 4-2 apply to shares admitted to trading on a regulated market of an issuer having Norway as its home state.