Active Owners Denmark’s Ethical Guidelines

1. The members shall conduct business in a prudent manner

2. Investing members, who are Private Equity funds or other alternative investment funds, shall establish and comply with ESG principles. Other investing members will actively work with ESG principles.

3. All members will comply with legislation alongside other regulations, including other ethical guidelines a member may be subject to.

4. Investing members will work to ensure that their portfolio companies comply with relevant principles within these ethical guidelines, including paragraph 1, 3, 7, 10, 13, 14, 18 and 19.

5. Investing members who receive capital grants from investors, shall comply with rules set to prevent money laundering, just as one shall concern oneself of whether the investors are conducting their business in a legal fashion

6. Investing members shall work to ensure that their management, employees, advisors, portfolio companies etc. are familiar with these ethical guidelines.

7. Members will abstain from contributing to the violation of these guidelines from other members.

8. Investing members, who are completely or partly comprised by the Active Owners Denmark Guidelines for Responsible Ownership and Corporate Governance in Private Equity firms, shall comply with the Guidelines alongside working to ensure that their portfolio companies also comply with relevant principles in the Active Owners Denmark Guidelines

9. Investing members, who are headquartered outside of Denmark, and who are comprised by another the guidelines of another country for responsible ownership and corporate governance, shall comply with said guidelines.

10. If an error or mistake occurs, the member shall seek to correct this error and work to ensure that the mistake is not repeated. 11. Investing members will submit accurate Annual Reports and ongoing updates.

12. Investing members will make all relevant information known before the entering of agreement with investors.

13. Members will only promise what the member realistically can keep, including non-legally binding promises, just as the members will strive to keep said promises.

14. Investing members aim to ensure that agreements made are not unclear in their regulation of each party’s legal position.

15. An investing member will give potential contractors a realistic view of the investing member’s economic and competence abilities, to make sure that no negotiation is commences on spurious information.

17. The members will keep secret and omit misusing any confidential information that comes into their knowledge as business provider, investor or borrower or as an advisor to one of these, including but not limited to; during negotiations on a potential deal, also in cases where a confidentiality agreement is not entered.

18. The members will take appropriate action towards securing that confidential information is kept as such.

19. The members will neither make decisions that are damaging to Active Owners Denmark’s reputation nor to the reputation of the industry and the industry interests that the Active Owners Denmark represent.

20. Investing members will pass on overall information in investments made, exits, procured capital and so forth, so that the Active Owners Denmark is able to carry out information material, such as statistics, to its members and for the use of upholding Active Owners Denmark’s work as an opinion leader and influencer of public opinion. Active Owners Denmark will process the received information confidentially and provided information from the members will only be published in a brief format.

The Active Owners Denmark Ethical Guidelines were adopted by the Active Owners Denmark Board of Directors on January 4, 2019