^{Participation policy}

Description and publication of the participation policy
of FINVIA Capital GmbH pursuant to Section 134b AktG

FINVIA Capital GmbH is a securities institution pursuant to Section 2 (1) of the German Securities Institutions Act ("WpIG") and, as an asset manager within the meaning of Section 134a (1) No. 2 of the German Stock Corporation Act ("AktG"), is subject to the provisions of Sections 134b and 134c AktG. It must therefore describe and publish its participation policy within the meaning of Section 134b (1) AktG.

FINVIA Capital GmbH does not exercise any shareholder rights on behalf of its clients. No general meetings are attended, no voting rights are exercised for clients, notifications from public limited companies are only acknowledged as part of mandatory notifications and no active communication takes place with the company or other shareholders.

The participation policy was therefore defined as follows:
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1. As an asset manager, FINVIA Capital GmbH does not exercise any shareholder rights within the meaning of Section 134b (1) No. 1 AktG that are based on participation in the company. In particular, no rights relating to the general meetings of stock corporations are exercised. The right to a share in profits within the meaning of Sections 60 et seq. AktG and subscription rights are exercised in consultation with customers.
2. Important company matters within the meaning of Section 134b para. 1 no. 2 AktG are monitored by taking note of the legally required reporting of the companies in financial reports and ad hoc disclosures.
3. There is no exchange of opinions with corporate bodies and/or stakeholders of the company within the meaning of Section 134b para. 1 no. 3 AktG.
4. There is no cooperation with other shareholders within the meaning of Section 134b (1) No. 4 AktG.
5. If conflicts of interest arise within the meaning of Section 134b (1) no. 5 AktG, these are disclosed to the parties concerned in accordance with the statutory provisions and the further course of action is clarified with the parties concerned.
6. There is no annual reporting on the implementation of the participation policy within the meaning of Section 134b (2) AktG, as no corresponding rights are exercised.
7. Voting behavior within the meaning of Section 134b (3) AktG is not published as there is no participation in voting.

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