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AIFM GROUP

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AIFM Capital AB · org. 556737-5562 · FI identification no. 35204. Authorised by Finansinspektionen to manage UCITS funds and alternative investment funds.

© 2026 AIFM Group AB

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Regulatory information

Policies & disclosures

Publicly disclosed policies, information and lists. Some documents are available in Swedish only.

  • Information on incentive (Swedish)

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  • Remuneration policy (Swedish)

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  • Information on best execution (Swedish)

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  • Sustainability risk Policy (Swedish)

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  • List of partners

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  • List of counterparties when placing orders for execution

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Governance & investor information

Exercise of voting right

An AIFM shall develop adequate and effective strategies for determining when and how any voting rights held in the AIF portfolios it manages are to be exercised, to the exclusive benefit of the AIF concerned and its investors. To comply with this, AIFM has adopted and implemented internal guidelines for exercising voting rights. According to our ownership policy, we shall always vote with the common interest of the investors of the fund. This shall be done if AIFM, through its funds, are among the largest shareholders of the issuer, or if it is considered to be beneficial for the funds return. Voting can only be exercised in accordance with the funds investment policy and/or strategy. In most circumstances, AIFM does not exercise active ownership except for funds investing in non-listed companies. However, AIFM continously monitors the development of all funds’ portfolio companies. When voting rights are exercised, AIFM shall always  act in accordance with relevant laws and regulations and otherwise according to good practice in the stock market.

Measures against money laundering and terrorist financing

The board of directors has appointed Olle Lyrfors as responsible for the anti-money laundering function and he will act as the officer for controlling and reporting obligations.

Olle Lyrfors

olle.lyrfors@aifm.se

00(46)72-589 82 71

Sustainability

Sustainability criteria is applied to some of the funds managed by AIFM. Information on sustainability critera for funds managed by AIFM can, in applicable cases, be found in each fund’s respective prospectus here.

Read about sustainability and SFDR disclosures.

Market Soundings

AIFM does not participate in market soundings. If AIFM wishes to participate in future market soundings, this will be disclosed.

Conflicts of interest

In order to comply with the regulation and to maintain the public’s confidence in the financial market and for the group, AIFM has established, implemented, and applied an internal policy for preventing, identifying, managing, and monitoring conflicts of interest. The internal policy is evaluated and re-approved at least once per year by the board of directors.

Depositary

AIFM uses the following providers as depositary for the funds:

  • Skandinaviska Enskilda Banken AB – org. no. 502032–9081
  • Swedbank AB – org. no. 502017-7753
  • CSC Depositary Services (Sweden) AB – org. no. 556944–1172
  • Got Your Back Depositary Services AB – org. no. 559295-3706

Complaints

If you are not satisfied with our services, it’s important that you contact us as soon as possible.

If you have a complaint, you should first contact the employee at the AIFM, with whom you have been in contact regarding the matter the complaint concerns. If you are still dissatisfied after this, you can proceed by contacting the AIFM’s complaints officer in writing.

When submitting a written complaint (by letter or email), you should describe in detail what you are dissatisfied with and what has happened. Also attach copies of relevant documents. It is preferable that you state which employees you have been in contact with regarding the matter, as well as when these contacts took place.

The company aims to respond to the complaint as promptly as possible. If we are unable to respond to your case within 14 days of receiving the complaint, you will receive written information about this, as well as information about the further handling of your case.

If you would like guidance regarding your complaint, you can get help from your municipality’s consumer guide (see your municipality’s website). You are entitled to free advice from The Swedish Consumers’ Banking and Finance Bureau (Konsumenternas Bank- och Finansbyrå). See www.konsumenternas.se. You also have the option of taking the matter further to the National Board for Consumer Disputes (Allmänna Reklamationsnämnden, ARN), or to a general court. See www.arn.se for information about the National Board for Consumer Disputes.

The complaint should be sent to the recipient below:

Complaints manager:

Robert Bratt

AIFM Capital AB

Attn: Complaints Officer

Box 902

392 33 Kalmar

robert.bratt@aifm.se

00(46)70-817 58 72

Investment risk

Historical returns are no guarantee of future returns. The money that is invested in the fund can both decrease and increase in value and it is not certain that the investor will get back all the deposited capital. A fund with risk classes 6-7 can both shrink and increase significantly in value, due to its composition and the management methods used. We recommend that you take note of the fund’s fact sheet, information brochure and fund regulations before investing.