Investor Relations Policy

The overall target for the IR activities is to ensure that the Company complies with the laws and regulations that are applicable for a company listed on Euronext Growth. The Company’s IR activities shall ensure that all participants in the financial markets have simultaneous access to accurate, clear, relevant and complete information about the Company’s performance and market position, in order to give the financial markets a precise picture of the Company’s financial position and other factors that may influence value creation in the Company. 

This will help ensure that: 

(a) the market price of the Company’s shares reflects the real value of the Company; 

(b) the Company’s shares remain as liquid as possible; and 

(c) the Company maintains access to capital markets, as well as reducing the cost of capital. 

Through an open and close dialogue with financial market participants, the investor relation function shall also contribute to the views and comments of market participants being made known to the management of the Company. 

The Company has implemented a manual on disclosure of information and handling of inside information which facilitates compliance with the relevant rules and regulations. 

The board of directors shall review and evaluate the content of this manual at least annually.

Correct and proper long-term assessment of the Company’s shares depends on consistent and credible communication, the creation of well-founded expectations within the financial community – including shareholders, analysts and potential new investors – and consistent fulfilment of any expectations the company has helped to create. 

The IR-function shall ensure continuous, precise and transparent communication with the Company’s shareholders, investors, analysts and other stakeholders.

Responsibility for the investor relations function lies with the Chief Financial Officer, who reports investor related matters to the Company’s board of directors. The investor relations function will be responsible for all contact with third parties relating to the Company’s financial results, strategy, legal processes, acquisitions or disposals, or any other kind of inside information.

The investor relations function shall not comment on market rumours, analyst estimates etc. The investor relations function is also responsible for regularly initiating updating of these guidelines upon changes in applicable regulations.

The investor community shall be given the opportunity to equal and simultaneous information about the Company. The Company’s contact with the investor community should be neutral. 

The investor relations function is responsible for the Company’s contact with shareholders and the investor community, except in the matters of elections of board members. This work is led by the board of directors collecitevlycollectively carrying out the duties of a nomination committee. 

The investor community is free to contact the Company and the investor relations function will normally be the one who has regular contact with these. The investor relations function should facilitate shareholders’ and other stakeholders’ opportunity to provide direct input and discuss specific issues, always having due regard to the aim of ensuring equal and simultaneous information to the financial markets.

The financial reporting shall comply with the framework set out in Euronext Growth’s Rule Book Part I and II. In addition, the Company should comply with relevant recommendations and market practices for financial and other investor information. 

The Company should as far as possible follow the Norwegian code of practice for corporate governance, including the code’s principles of transparency and disclosure of relevant information. 

The Company seeks to at all times comply with the latest version of the “Oslo Børs’ IR recommendation”. Compliance with the recommendation is based on a “comply or explain” principle, which means that the Company’s website shall explain any deviations from the recommendation under “Investor Relations.” 

All written financial information shall as a main rule be published in English.

Work related to and received drafts of analysis and financial models prepared by analysts may be reviewed and commented on by the investor relations function. The Company’s comments on such drafts or models shall be limited to the following: 

(a) Corrections of inaccurate historical public information; #9785616/6 39 (63) 

(b) Deviations from the information and forecasts the Company has published that specify, without confirming, the date and / or cause of publication; 

(c) Non-material information, whether in the public domain or not; and 

(d) Industry related information. 

It should be emphasized that the Company has not undertaken any obligation to update any kind of forward-looking statements the Company provides or has provided, and that the Company, as a matter of policy, does not “commend”, “support” or say “it is comfortable with” any analyst report and / or financial model.

Investor and analyst meetings will, as a main rule, not be held in the four last weeks prior to the publication of financial reports. In the same period the Company shall furthermore not provide comments to the press or others regarding the Company’s results and prospects.

The Company does not comment on market rumours or speculations. The Company shall regularly monitor online news providers, chat rooms and other sites, in order to identify statements regarding the Company. Authorized spokespersons of the Company may, after careful consideration, react if a rumour or speculation is causing market volatility or Oslo Børs requests that the Company makes a statement.

The Company does not comment about its competitors, and should suggest that anyone asking about competitors call the competitor for information.

The IR function is responsible for keeping the insider register updated in accordance with laws and regulations.