NORTH ENERGY
ADDITIONAL REGULATED INFORMATION REQUIRED TO BE DISCLOSED UNDER THE LAWS OF A MEMBER STATE
Additional Agenda Item for EGF — Proposal for Investigation
With reference to notice on 15 April 2026 regarding a request for an extraordinary general meeting (the EGM), the Board has received a new request from shareholder Anti-Gravity AS to include a proposal for an investigation pursuant to the Norwegian Companies Act section 5-25. The investigation requested relates to the board and managements actions in the period from 15 April to 15 May 2026, and specifically whether the share purchases made by persons discharging managerial responsibilities (PDMRs) on 16 April 2026 have occurred within a closed period and whether their handling of the EGM request and the trades may represent a breach of the equal treatment and fiduciary principles.
The request rests on an incorrect reading of MAR Art. 19(11) and otherwise has no merit or basis in applicable law. MAR Art. 19(11) defines closed periods in relation to a mandatory interim financial report or a year-end report which the issuer is obliged to make public. Q1 reports published voluntarily by the Company do not constitute mandatory financial reporting under MAR. Furthermore, the trades were agreed and executed after publication of the request for the EGM.
Notwithstanding that the investigation request concerns legal assertions lacking merit, rather than factual matters, and that it was submitted after the deadline for proposing agenda items, the Board intends to nonetheless include the proposal on the agenda as requested. The notice of the EGM will be published on 21 April 2026 and will set out the Board's recommendations to the general meeting.