Greenvale Capital LLP

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 98 73 Greenvale Capital LLP Legal/Compliance 1 Vere Street London, W1G 0DF UNITED KINGDOM Our reference 25/7266 Your reference 17.10.2025 Decision on violation penalty Reference is made to the letters from the Financial Supervisory Authority of Norway (Finanstilsynet) dated 19 June and 4 September 2025, and the reply received from Greenvale Capital LLP (Greenvale Capital) on 1 July and 15 September 2025. Greenvale Capital sold shares in Aker Carbon Capital (ACC) on 16 May 2025, but the transaction in ACC was notified to the market on 23 May 2025 at 16:30 (CET). Based on the information made available, the preliminary view of Finanstilsynet is that Greenvale Capital notified the market too late and violated the Norwegian Securities Trading Act (NSTA) section 4-2 cf. section 4-4. On this background, Finanstilsynet has decided to impose a violation penalty in the amount of NOK 100 000 on Greenvale Capital, cf. NSTA section 21-3. 1 Legal basis Pursuant to the NSTA section 4-2, a shareholder shall immediately notify the regulated market of a transaction which causes the shareholder's proportion of shares to 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.