Lucerne Capital Management LP

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 Lucerne Capital Management LP 73 Arch Street 3rd Floor Greenwich, CT 06830 USA Our reference 25/11681 Your reference 17.12.2025 Decision on violation penalty Reference is made to the letters from the Financial Supervisory Authority of Norway (Finanstilsynet) dated 23 June, 27 October and 2 December 2025, and to the reply from Lucerne Capital Management LP (Lucerne) dated 26 August and 20 November 2025. Lucerne purchased shares in Agilyx ASA (AGLX) and exceeded the 5 % disclosure threshold in Norwegian Securities Trading Act (NSTA) section 4-2 on 23 February 2024. The transaction was notified to the market on 28 August 2025. Further, Lucerne sold shares in AGLX via a forward contract on 25 February 2025, retaining the right and obligation to repurchase the same number of shares at a predetermined date and price, falling below the 5 % threshold in NSTA section 4-2 cf. 43. This transaction was notified to the market on 3 November 2025. Based on the information available, Finanstilsynet has concluded that Lucerne has violated the NSTA section 4-2 and 4-3 and has decided to impose a violation penalty of NOK 125.000 on Lucerne, cf. NSTA section 21-3.