Topdanmark A/S : Information on the data protection law related matters AGM 2022 (41 KB)

February 2022

Information on data protection law related matters

in connection with the annual general meeting

Topdanmark A/S • Borupvang 4 • 2750 Ballerup • Denmark

Tel [phone] • CVR no. 78040017

www.topdanmark.com• E-mail:[e-mail]

1. Introduction

The purpose of this information sheet is to provide you as a shareholder, proxy holder or advisor with certain information as to the collection, processing and storing of personal data in connection with the holding of the annual general meeting in Topdanmark A/S, CVR no. 78 04 00 17, Borupvang 4, DK-2750 Ballerup (the "Company"). According to the Company's articles of association the Annual General Meeting will be held as a fully virtual AGM without the possibility of physical attendance.

The Company acts as the data controller, which implies that the Company is responsible for your personal data being properly processed. If you have any questions, please contact the Company's Data Protection Officer by sending an email to: [e-mail].

Below you will find a description of the information, which the Company may collect, process and store, as well as of the purpose of and the background for procession the information.

In sections 2-3 certain general information is provided in respect of convening general meetings, the publication of documents, registration of participation, granting proxy and voting by post. Sections 4-9 concern a number of more specific issues, including submitting questions prior to the general meeting, submitting proposals to be transacted at the general meeting, the right to speak and posing questions at the general meeting, webcast, holding a virtual AGM, and minutes of the general meeting.

Reference is made to Company's privacy and cookie policy, which is available on the website.

2. Notice of general meeting

Notice of a general meeting in the Company must be submitted based on the information registered in the register of shareholders, including information on name, address and any email address. The Company will in this respect process your personal data for the purpose of forwarding the notice of the annual general meeting to the shareholders, including enabling the shareholders to exercise their fundamental administrative rights at the general meeting.

The notice of the general meeting including the agenda will be published and forwarded in accordance with applicable law and the Company's articles of association and will thus be published as a company announcement through Via Ritzau, on the Company's website, via the Danish Business Authority's it-system and be forwarded by email or ordinary mail to the shareholders, who have requested this.

In continuation of the publication of the notice of the general meeting, certain other documents relevant for the general meeting will be published on the Company's website, including the complete proposals and forms to grant proxy or vote by post.

The Company's processing of your personal data in connection with the notice convening AGMs as described above serve to ensure that the Company comply with legal obligations in accordance with the Danish Companies Act, and thus, the processing is carried out in order to meet a legal requirement cf. Article 6 (1) 1 (c) of the General Data Protection Regulation.

The notice of the general meeting including the agenda and other documents relevant for the general meeting will be available on the website for a period of up to 6 years.

The Company may store the notice of the general meeting including the agenda, the complete proposals and forms for granting proxy and voting by post, until it is no longer necessary for the Company to store the information in order to protect the Company's and the shareholders' interests, however for a period of at least 10 years, following which it will be deleted.

3. Notification of participation, granting proxy and voting by post

Notification of your participation implies that the Company will process your personal data based

on the information registered about you in the register of shareholders. The processing of your personal data also takes place in connection with granting voting proxy, proxy to the board of directors or with voting by post. Similarly, processing of your personal data will take place, if you vote at the general meeting.

If you grant proxy to a third party and/or register attendance of an advisor, the Company will collect and process personal data about such persons (name and address). Collecting and processing data takes place for the purpose of ensuring that the relevant persons can participate in the Company's general meeting and ensuring that they can exercise their rights.

Therefore, the Company processes the personal data in order to comply with the Company's legal obligations in accordance with the rules on shareholder rights in the Danish Companies Act, and thus, the processing is carried out in order to meet a legal requirement cf. Article 6 (1) 1

(c) of the General Data Protection Regulation.

The Company may store information about registration of attendance, proxies and postal votes until it is no longer necessary for the Company to store the information in order to protect the Company's and the shareholders' interests, however, for a period of at least 10 years, following which the information will be deleted.

4. Submitting questions prior to the general meeting

When submitting written questions prior to the general meeting, you must document your status as a shareholder or a proxy holder, and in this respect collection and processing of your personal data will take place. Collection and processing of personal data will in such event be based on the Company's legitimate interests in being able to identify you, in order for you to be able to exercise your rights as a shareholder to submit questions cf. Article 6 (1) 1 (c) of the General Data Protection Regulation.

If questions are replied to in writing, the questions and the Company's replies, including your name, will be presented at the general meeting.

The Company may store information about questions submitted until it is no longer necessary for the Company to store the information in order to protect the Company's and the shareholders' interests, however, for a period of at least 10 years, following which the information will be deleted.

Reference is also made to section 6 concerning the right to speak and pose questions at the general meeting.

5. Submission of proposals

In connection with a request for including a specific issue on the agenda for the general meeting, your personal data and the contents of the proposal will be collected and processed by the Company. Your personal data will in this respect be collected based on the Company's legitimate interests in being able to identify you as a shareholder in order to enable you to exercise your right to submit proposals to be included on the agenda, cf. Article 6 (1) 1 (c) of the General Data Protection Regulation.

If your request fulfils the requirements, the proposal and your name will be included (i) on the agenda and in the complete proposals and (ii) on the forms for granting proxy or voting by post, which will subsequently be published in accordance with the rules in this respect.

Reference is also made to section 2 concerning the notice of general meeting and section 9 concerning the preparation of the minutes of the general meeting.

6. The right to speak and pose questions at the general meeting

If you choose to speak at the general meeting, e.g. in order to pose questions to the board of directors' report or the annual report, you will be requested to document that you are a

shareholder or a proxy holder, and in this respect personal data about you will be collected and processed based on the Company's legitimate interests in being able to identify you in order for you to exercise your right to speak and potentially pose questions at the general meeting, cf.

Article 6 (1). 1 (c) of the General Data Protection Regulation.

Reference is also made to section 7 concerning webcast and section 9 concerning the preparation of the minutes of the general meeting.

7. Webcast

The general meeting will be webcasted live on the Company's website. The recording will also be available on the Company's website after the general meeting.

The recording, which includes both picture and sound, will cover the podium and the platform at the general meeting, and thus your personal data will be collected and processed, if you choose to speak at the general meeting. Before you address the assembly, you must document your status as a shareholder or proxy holder, and by speaking from the platform (e.g. in connection with posing a question in respect of the annual report) you accept the Company's collection and processing of your personal data, including your name and your picture, in connection with the recording. You cannot insist on not being recorded, if you choose to speak at the general meeting.

Your personal data will be collected based on the Company's legitimate interests in being able to identify you as a shareholder or proxy holder in order to enable you to exercise your rights at the general meeting, and in order to ensure transparency concerning the transactions at the general meeting, also in order for the shareholders, who are unable to attend the general meeting in person, to follow the proceedings by watching the recording.

The recording will be available on the Company's website for a period of 1 year after the general meeting, following which it will be deleted.

Livehouse Europe ApS will process your data on behalf of the Company. The processing will take place in Denmark. The Company and Livehouse Europe ApS have entered into a data processing agreement in order to ensure that Livehouse Europe ApS has implemented proper technical and organisational measures to protect your personal data.

8. A fully virtual annual general meeting

The annual general meeting will be held as a fully virtual event, and the annual general meeting will be transmitted live via streaming (webcast) in the annual general meeting portal. The annual general meeting will also be transmitted live at Topdanmark's website www.topdanmark.com.

The transmission will also be available at the Company's website after the annual general meeting.

The recording will include both sound and images, and it will cover the AGM's podium and rostrum. Personal data will be collected and processed if you choose to take the floor. Before you take the floor, or your question is read aloud, you must document your status as a shareholder or a proxy holder, and when virtually taking the floor, you accept the Company collecting and processing your data, including name and image in connection with the recording. If taking the floor, you cannot decline being recorded.

Collection of your personal data is based on the Company's legitimate interests in being able to identify you as a shareholder or a proxy holder, in order for you to be able to exercise your rights at the annual general meeting as well as ensuring transparency about the discussions at the annual general meeting cf. Article 6 (1) 1 (c) of the General Data Protection Regulation.

The recording will be available at the Company's website for a period of one year after the annual general meeting, after which it will be deleted.

9. Minutes of the general meeting

After the general meeting, the Company will prepare minutes of the general meeting, and therefore your personal data may, in continuation of the original collection and processing of your personal data, e.g. when submitting proposals, cf. section 5, or when exercising the right to speak at the general meeting, cf. section 6, be additionally processed in this respect. The minutes must be prepared in accordance with the Danish Companies Act, and the procession of your personal data thus takes place in order to comply with at statutory requirement, cf. Article 6

(1) 1 (c) of the General Data Protection Regulation.

When submitting a proposal to be included on the agenda, it is not possible to insist on not having your name stated in the notice of the general meeting (or in forms) and thus you cannot insist on not having your name stated in the minutes either.

The minutes of the general meeting will be made available in the Company's website for a period of up to 6 years, and the minutes will thus during this period be available to the shareholders and to the general public.

The Company may store the minutes of the general meeting until it is no longer necessary for the Company to store the information for the purpose of protecting the Company's and the shareholders' interests, including for the purpose of the documenting the transactions and resolutions made at the general meeting. This implies that minutes will not be deleted.