• General Privacy Notice

• Code of Ethics

• Conflicts of Interest Policy

• Finance Policy

• Governance Policy

• Information and Trading Policy

• Information Security and Data Privacy Policy

• EQT Foundation Responsible Investment & Ownership Policy

• Modern Slavery Act Statement (where applicable)

• Global Workplace Health and Safety Guidelines

• Anti-Bribery & Corruption Guidelines

• Diversity and No-Harassment Guidelines

• Tax Guidelines

• Business Partner Code of Conduct

• Remuneration Public Disclosure Statements (where applicable)

• Risk Management Guidelines

Anti-Bribery & Corruption

EQT Foundation is committed to complying with applicable anti-corruption and anti-bribery laws wherever it conducts business. EQT Foundation does not accept, offer, request, or authorize bribes in any form.

Political contributions, gifts, and business entertainment may be considered forms of bribery depending on local law and context. EQT Foundation maintains internal guidelines governing gifts, hospitality, and interactions with public officials. All gifts or business entertainment offered or received by staff must comply with the applicable internal approval processes and documentation requirements.

These guidelines apply to all staff and are designed to prevent improper influence, including where interactions involve public sector counterparties or state-owned entities, and to ensure that EQT Foundation does not obtain business or favorable treatment in exchange for political contributions, fundraising assistance, or any improper benefit.

To promote sustainability in our industry and support constructive public discourse, EQT Foundation may participate in industry associations, working groups, and other initiatives.

Trade associations & partnerships (disclosure):
EQT Foundation’s contributions to trade associations and other key partnerships are disclosed in accordance with applicable transparency expectations and internal governance.

The contributions primarily consist of membership fees and dedicated studies. The three largest contributions during 2024 were made to [Partner 1], [Partner 2], and [Partner 3].

Political contributions:
EQT Foundation does not make political contributions to political parties, political organizations, or election candidates. In line with this approach, no donations have been made from [Year] to date, and no political expenditure has been incurred. While EQT Foundation does not participate in party political activities, we may engage in policy debate on subjects of legitimate concern to our mission, stakeholders, and the communities in which we operate.

Disclaimer (scope of historical data):
Where historical disclosures are presented, earlier periods may reflect different organizational structures or reporting boundaries. If applicable, historical data prior to a given year may not include certain subsidiaries or legacy operations. Since contributions primarily consist of membership fees, detailed disclosure regarding specific lobbying initiatives may not be feasible.

Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF)

EQT Foundation is committed to preventing money laundering and terrorist financing and to complying with applicable AML/CTF laws and regulations relevant to its activities and business relationships.

EQT Foundation maintains an AML/CTF program consisting of appropriate policies, procedures, training, and controls designed to help prevent, detect, and manage risks related to money laundering, terrorist financing, sanctions breaches, and related financial crime.

To ensure oversight of AML/CTF matters, EQT Foundation designates responsible compliance personnel to oversee due diligence and program governance.

EQT Foundation applies a risk-based approach to determine:

• the scope of due diligence,

• the level of ongoing monitoring, and

• whether enhanced measures are required.

Enhanced due diligence may be applied where relationships involve high-risk jurisdictions, complex ownership structures, politically exposed persons (PEPs), correspondent relationships (where applicable), or other elevated risk indicators. Relationships involving PEPs are subject to dedicated monitoring and appropriate approvals.

EQT Foundation may conduct screening of counterparties and relevant related parties (including ultimate beneficial owners) against:

• Sanctions lists published by the United Nations and the European Union, and relevant sanction authorities such as the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC);

• PEP databases to identify politically exposed persons;

• Other relevant watchlists and risk intelligence sources, where appropriate.

All data collected in connection with client identification and AML/CTF controls is documented, and records are retained for a minimum of five (5) years, or longer where required by applicable law.

Global Disciplinary Misconduct Framework

EQT Foundation maintains a Global Disciplinary Misconduct Framework under which alleged conduct that materially conflicts with our values, policies, guidelines, and procedures is handled through structured escalation and review. This includes, for example, misconduct relating to fraud, financial and other crimes, legal and regulatory breaches, data breaches, and employment practice misconduct.

The framework is designed to streamline and strengthen disciplinary processes, ensuring:

• proper escalation,

• consistent assessment and treatment of cases,

• clear documentation and closure processes.

Cases are assessed through an internal process involving relevant management, HR, legal counsel, and compliance functions, with oversight assigned to an appropriate governance body such as an audit committee or equivalent supervisory function.

Conduct that conflicts with EQT Foundation’s core values and policies is unacceptable and may result in disciplinary action, including impacts on discretionary incentives, written warnings, and/or termination of employment where appropriate and lawful.

On a periodic basis (e.g., quarterly), aggregated reporting on cases handled under the framework may be provided to the relevant oversight body.

Shareholder Rights Directive (SRD II) – Where Applicable

Where applicable, relevant EQT Foundation-affiliated entities may assess the impact of SRD II and related rules, including whether it is appropriate to develop and publish a shareholder engagement policy.

Whistleblowing

EQT Foundation maintains external whistleblowing instructions and an external whistleblowing channel. Details can be found here: [Whistleblowing Link Placeholder].

EQT Foundation’s Approach to Information Security Governance

EQT Foundation recognizes that security is not only a technical responsibility—it is a strategic enabler for trust, resilience, and long-term value creation. We are committed to protecting our systems, partners, and stakeholders from cyber, information, and operational risks.

By integrating strong security governance, EQT Foundation enhances the stability of digital infrastructure, increases stakeholder confidence, and safeguards the continued success of our operations and digital transformation.

Information Security Management Program

EQT Foundation’s Information Security Management Program incorporates business continuity, ICT risk management, vulnerability management, and internal controls. We maintain an ICT resilience strategy that includes structured methodologies for identifying and classifying risks, defining critical systems, and implementing mitigation plans. Where applicable, escalation procedures, designated approval paths, and tabletop exercises are established.

Our program is informed by globally recognized frameworks, where applicable, including:

• ISO/IEC 27001

• NIST Cybersecurity Framework

• EU Digital Operational Resilience Act (DORA) (where relevant)

• Industry resilience expectations aligned with our operating model

Vulnerability management is implemented through a combination of automated scanning and manual penetration testing. Remediation is prioritized based on risk and governed by documented timelines aligned with industry practices.

Cybersecurity is embedded within the organization’s Enterprise Risk Management (ERM) approach. Control effectiveness is reviewed through assessments supported by evidence and data insights where available. All staff undergo annual security awareness training to identify threats and follow escalation protocols. Selected systems may undergo independent external audits and certifications where appropriate.

Transparency and Breach Disclosure

EQT Foundation is committed to maintaining high standards of transparency and integrity. There were no material information security breaches in FY2024.