DISCLOSURE OF HOLDINGS

Reference is made to the stock exchange notices of 13 December 2010 (subscription and allocation of shares to primary insiders) and 20 December 2010 (minutes from extraordinary general meeting). As stated in the latter notice, the General Meeting of Dolphin Group ASA ("Dolphin") has resolved to issue 151,673,000 shares in a private placement ("Private Placement") and 7,990,000 subscription rights pursuant to § 11-12 of the Public Limited Liabilities Companies Act. The terms of the subscription rights are set out in the minutes enclosed the said stock exchange notice.

After completion of the Private Placement, the share holding of the following shareholders has fallen below 5 %:

Primary insider Atle Jacobsen, has subscribed for 1,000,000 shares and 1,598,000 subscription rights through his wholly owned company Three M AS. After completion of the Private Placement, Three M AS will hold 2,817,034 shares in Dolphin. In addition, a company controlled by close family members of Atle Jacobsen owns 25,000 shares in Dolphin. This implies that Jacobsen together with his family holds shares and subscription rights equal to 2.78 % of the registered share capital upon completion of the Private Placement (out of which the shares corresponds to 1.78 % of the registered share capital).

Primary insider Erik Hokholt, subscribed for 2,400,000 shares and 1,598,000 subscription rights through his wholly owned company Økonomi og Regnskapsbistand AS. This implies that Økonomi og Regnskapsbistand AS will hold shares and subscription rights equal to 2.5 % of the registered share capital upon completion of the Private Placement (out of which the shares equals 1.5 % of the registered share capital).

Consema AS where Dolphin's member of the board of directors and primary insider Hege Eikeland, is managing director, subscribed for 200,000 new shares in the Private Placement. After completion of the Private Placement, Consema AS will hold 950,000 shares corresponding to 0.59 % of the share capital.

Fjord Partners Invest AS has not subscribed for shares in the Private Placement and holds 2,500,000 shares corresponding to 1.56 % of the registered share capital upon completion of the Private Placement.