Topdanmark — Director's Dealing 2011

Dec 9, 2011

Capital Research and Management"

Capital Research and Management Company 333 South Hope Street Los Angeles, California 90071-1406

Phone (213) 486 9200 Fax (213) 4B6 9698

16 May 2011

BY FACSIMILE

$(4544681906)$

Topdanmark AS Communication/IR Department Borupvang 4 DK-2750 Ballerup

Re: Disclosure of Interest in Topdanmark AS

Dear Sir/Madam,

Please find attached a Standard Form 1 filed on behalf of Capital Research and Management Company ("CRMC"). CRMC is a U.S.-based investment adviser that manages the American Funds family of mutual funds. CRMC does not own shares of the companies it invests in for its own account. Rather, the shares reported in this disclosure are owned by mutual funds under the discretionary investment management of CRMC. CRMC is filing solely with respect to shares over which it exercises voting rights.

For the purpose of this Notice, an outstanding share balance of 15,666,550 shares was used to calculate the percentage of holdings. We believe this figure is correct; however, if this number is not accurate, please contact us as soon as possible so we may make the necessary revisions.

Should you have further questions or require additional information, please contact us at (213) 615-0469, or by facsimile at (213) 486-9698. Alternatively, you may contact us via e-mail at GRGroup@capgroup.com.

Sincerely,

Christopher Aquino Compliance Associate

cc: Finanstilsynet

STANDARD FORM 1

$1)$ The identity of the company issuing the underlying shares with voting rights, including the full name of the company and the type of company:

Topdanmark AS

• $2)$ Background for duty to notify (please cross one or more of the following boxes):
• 区 acquisition or sale of voting rights or share capital
• $\Box$ acquisition or sale of financial instruments which can enable acquisition of existing shares with voting rights
• $\Box$ an event which establishes or changes the ratio of share capital or voting rights
• $3)$ The identity of the shareholder or natural or legal persons covered by the duty to notify: 1)

Capital Research and Management Company

• The identity of the shareholder (if this is different from the person under point 3): $^{19}$ $4)$
• The date where the transaction took place and the date on which the threshold was $5)$ equaled or crossed: iii)

16 May 2011

The threshold which was equaled or crossed (as a percentage or fraction): $6)$

5%

7) Further information: (shareholders mentioned in section 3 must notify possession of share capital)

Information on the voting rights 191
Class of share $($ $ SIN$ $)$ reported		Situation as previously	Situation after the transaction or the event has taken effect vi
	No. shares	Voting rights stated as percentages or fractions vilì	No. shares		Voting rights stated as percentages or fractions
			Direct	Indirect	Direct	Indirect
Ordinary Shares (ISIN: DK001025953 $\bf{0}$	838,450	5,3518%		$\mathbf 0$		0.0000%
Information on the share capital [x]
Class of share (ISIN)	Situation as previously reported		Situation after the transaction or the event has taken effect
	No. shares	Share capital stated as	No. shares		Voting rights stated as percentages or fractions
		percentages or fractions	Direct	Indirect	Direct	Indirect
N/A
TOTAL A) based on the total holding
				B) Financial instruments
				Situation after acquisition or sale x(1)
Type of financial instrument xiii )	Date of cessation Xiv}	Date when the instrument can be exercised. For instruments with an exercise period, state the date on which the shares are acquired or can be acquired xv)			Percen tage of shares fivx	Percentage of voting rights
N/A
		TOTAL B
(in relation to all cessation dates)

Total 1 $(A+B)$ xvii	Percentage of shares	Percentage of voting rights
	0.0000%	0.0000%

$\hat{\boldsymbol{\epsilon}}$

• If there are group considerations, state the chain of the controlling undertakings 8) through which the voting rights or share capital are actually held: ⁸
• $9)$ If there are group considerations, state the chain of the controlling undertakings through which the financial instruments are actually held: xix)
• $10$ In cases involving proxies, cf. section 4, no. 8 and section 5(3): the date for cessation of the proxy right, the situation after cessation of the proxy right as well as the identity of the shareholder, if relevant:

Situation after cessation of proxy rights:
Full name of a)	Date of	Percentage of voting rights		Percentage of Shares
the proxy and b) the shareholder(s)	cessation	Direct	Indirect	Direct	Indirect
a)
h
Total (for the proxy)

11) Further information:

Pursuant to letter of application of 7 February 2008 from The Capital Group Companies, Inc. ("CGC") to the Danish FSA regarding the exemption requirements for parent companies under Executive Order 1225 section 12 and 14, CGC will no longer report interest in securities in Denmark on its own behalf. Instead voting interest and ownership in shares will be reported separately by Capital Research and Management Company ("CRMC"), Capital Group International, Inc. ("CGII") or the mutual funds and clients themselves, as appropriate.

CRMC is an investment adviser based in the United States and a 100% owned subsidiary of CGC. Neither CGC nor CRMC owns shares of Danish issuers on their own behalf. Rather the shares reported in this notification are owned by mutual funds under the discretionary investment management of CRMC. Certain mutual funds managed by CRMC have delegated the right to vote the proxies of their portfolio securities to CRMC. CRMC herby submits this report to reflect the shares over which CRMC has voting discretion.

Should a fund managed by CRMC vote proxies of its portfolio securities itself, the fund will submit a separate filing as appropriate.

$12)$ Date, place and signature

Walter R. Burkley 16 May 2011 Los Angeles, California