‍4L Capital AG (the “Institute”) is subject to the provisions of Sections 134b and 134c of the AktG as an asset manager within the meaning of Section 134a (1) No. 2 of the AktG and must therefore describe and publish its voting rights policy within the meaning of Section 134b (1) of the AktG.

The Institute does not exercise any shareholder rights on behalf of its clients. No general meetings are attended, no voting rights are exercised on behalf of clients, only obligatory notices from public limited companies are acknowledged, and no active communication takes place with the company or with other shareholders.

Therefore the shareholder engagement policy is as follows:

(1) The Institute does not exercise any shareholder rights within the meaning of Article 134b (1) no. 1 of the AktG that are based on engagement with the company. In particular, no rights related to general meetings of public limited companies shall be exercised. The right to a share in profits within the meaning of §§ 60ff. of the AktG as well as to subscription rights are exercised in consultation with the clients.

(2) The monitoring of important matters of the companies within the meaning of § 134b para. 1 no. 2 of the AktG is carried out by taking note of the legally required reporting by the companies in financial reports and ad hoc announcements.

(3) here is no exchange of opinions with corporate bodies [representatives?] and or stakeholders of the company within the meaning of section 134b (1) no. 3 of the AktG.

(4)There shall be no cooperation with other shareholders within the meaning of section 134b (1) no. 4 of the AktG.

(5) If conflicts of interest within the meaning of § 134b para. 1 no. 5 of the AktG arise, these are disclosed to the persons concerned in accordance with statutory requirements and the further procedure is clarified with the persons concerned.

(6) There shall be no annual reporting on the implementation of the shareholder engagement policy within the meaning of section 134b (2) of the AktG, as no corresponding rights are exercised.

(7) There shall be no publication of the voting behaviour within the meaning of § 134b para. 3 of the AktG, as no participation in voting takes place.