Fidelio Capital II AB, reg. no. 559109-8818, and Fidelio Capital AB, reg. no. 559355-3505 (jointly referred to as “Fidelio” or the “Company”), are internally managed alternative investment funds subject to the supervision of the Swedish Financial Supervisory Authority. Fidelio is regulated mainly by the Swedish Alternative Investment Fund Managers Act (2013:561) (the “Act”) and Commission Delegated Regulation (EU) No 231/2013 (the “Regulation”).

In accordance with Chapter 8, Sections 19–20 of the Act and Articles 30–36 of the Regulation, Fidelio's Board of Directors has adopted a Conflicts of Interest Policy to identify, prevent, manage, monitor and, where necessary, disclose conflicts of interest that may arise in its activities and adversely affect the Fund or its investors.

Identification of conflicts of interest

Conflicts identified by Fidelio include business conflicts inherent to the management of the Fund, interests in competitors or other funds, inducements, personal transactions, business opportunities, outside employment, employee loyalty, redemption of investments, and the integration of sustainability risks.

Management of conflicts of interest

Such conflicts are managed through measures including control of information, segregation of duties, separate supervision, removal of inappropriate remuneration links, control over inappropriate influence and, where relevant, consultation with the Investor Committee. The CEO is responsible for managing conflicts of interest within Fidelio.

Disclosure of conflicts of interest

Where the arrangements made to manage a conflict are not sufficient to prevent risk of damage to the Fund or its investors, the general nature and/or sources of the conflict will be disclosed to investors on a durable medium before any affected business is undertaken.

Information updated: June 2026.