Ownership policy Purpose Lannebo Fonder AB’s, hereinafter Lannebo Fonder or the fund company, primary business objective is to generate the highest possible return for unit holders taking into consideration the funds’ objectives, investment policies and risk profiles. The purpose of exercising ownership rights is to promote the positive development of the companies the funds of Lannebo Fonder invest in. Good corporate governance promotes the possibility of a company’s long-term sustainable development. The role of owner should be exercised in such a way that a company’s value, and consequently the funds’ long-term returns, best develop in the common interest of unit holders. Lannebo Fonder considers responsible ownership an important part of the mandate from unit holders. Owner engagement activities are determined based on a risk and materiality assessment. The Board of Lannebo Fonder has established a policy providing guidelines for ownership engagement in the companies it invests in through the funds. The policy applies to all funds managed by Lannebo Fonder. Nomination Committees Lannebo Fonder participates in the Nomination Committee of those companies where the fund management company is one of the largest shareholders, provided that the design of the Nomination Committee is such that the fund management company's freedom of action is unrestricted. The Nomination Committee should consist of the company’s largest shareholders. The Nomination Committee's most important tasks include evaluating the existing board and proposing any board member changes, putting forth proposals for renumeration of board members, the chairperson, committee members and the committee chairpersons, as well as putting forth proposals of auditors and of the chairperson of the Annual General Meeting. Lannebo Fonder ensures that the principles for the nomination process are transparent and that this work is carried out effectively. Lannebo Fonder considers it of utmost importance to take into account diversity, skills, experience and gender balance when appointing members to a board. The board shall also otherwise meet the requirements of the Swedish Code of Corporate Governance. A board director should not have other duties to such an extent that he or she cannot devote sufficient time and care to the board assignment and contribute actively to effective board work. A board should normally have five to seven members. Board representation Lannebo Fonder exercises its ownership role without requiring board representation, as an appointment to the board would hamper effective management of the funds. Annual General Meeting The Annual General Meeting is the company’s highest decision-making body, where shareholders have the right to exercise their influence and make their voices heard. Companies must comply with the rules regarding owner engagement as required by law, relevant codes and guidelines, and otherwise to act in accordance with good market practice. Lannebo Fonder's guiding principle is to participate in meetings where the fund management company has shareholdings, except if the size of the holding is small relative to the other shareholders. Practical considerations determine participation at the General Meeting of foreign companies. When Lannebo Fonder participates at the General Meeting of a company shares on loan are recalled well in advance of the meeting. Internal guidelines determine which general meetings Lannebo Fonder should attend. Dialogue Lannebo Fonder's view is that companies that are managed responsibly and sustainably will perform better over time. Therefore, Lannebo Fonder expects that the companies they invest in are managed sustainably and responsibly; act in accordance with national and international laws and conventions; follow relevant codes and guidelines; and otherwise act in accordance with good practices in the equity market. In September 2013 Lannebo Fonder became a signatory of the UN directives for Responsible Investments (UNPRI - United Nations Principles for Responsible Investment). It is a voluntary framework that consists of six principles including environmental, social and governance aspects in the investment process, as well as in the ownership responsibilities. As a major shareholder in many companies Lannebo Fonder has an opportunity to exercise influence over the companies. Lannebo Fonder makes use of this possibility through proactive, as well as reactive, continuous dialogue with companies where the funds are shareholders. Lannebo Fonder also conducts structured sustainability meetings with senior executives of specific companies to discuss their sustainability efforts. These meetings are prioritized because they provide the fund manager with further knowledge for the investment analysis and the companies receive additional input regarding shareholder expectations. Companies are selected based on a risk and materiality assessment. In the case Lannebo Fonder is not satisfied with the development or management of a company, and the fund company does not have the possibility to influence through exercise of voting rights, divestment of the holding is an option. Lannebo Fonder shall consider collaborating with other shareholders in the event that this is appropriate and is in the common interest of unitholders. The scope of this work is governed through the Lannebo Fonder board adopted Policy for Responsible Investments. Share-based incentive programs Lannebo Fonder is positive to balanced share-based incentive schemes for a company’s employees in which the funds are shareholders. Incentive programs should be designed to promote the long-term ownership of shares. The allocation should normally be based on a clearly defined personal investment and goal attainment. Lannebo Fonder deems that those participating in the incentive program must take some form of financial risk, which means that fully subsidized programs or free allocation of stock options, shares or similar instruments are typically not suitable. Lannebo Fonder also considers that the company’s board should obtain approval for the proposed incentive programs from major shareholders well in advance of the Annual General Meeting. Conflicts of Interest Any conflicts of interest that may arise in connection with the use of voting rights on behalf for the funds is managed in accordance with the fund company's internal rules on the management of conflicts of interest. Other Lannebo Fonder monitors and analyses developments in the companies the funds have invested in on an ongoing basis through relevant market channels and direct contact with the companies. In this way, Lannebo Fonder can identify the need for dialogue with relevant companies at an early stage. The management organization and Head of Corporate Governance uphold surveillance of the companies. Lannebo Fonder reports retrospectively to unitholders positions adopted, including the rationale, in important individual ownership issues. Unitholders wishing to partake in all of the standpoints the fund management company made in regard to ownership issues can request this information free of charge. Generally, Lannebo Fonder believes the principle of "one share - one vote” should prevail. Contact person Mats Gustafsson is Head of Corporate Governance.