IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE AHUVA SCHACHTER, MICHAEL SMITH, DOUGLAS NEUJAHR, SAMHITA GERA, AND DENISH BHAVSAR, Individually and on Behalf of All Others Similarly Situated, Plaintiffs, C.A. No. 2023-1112 NAC v. IAN ROBERTSON, KEN MANGET, CHRISTOPHER JARRATT, MICHAEL HOFFMAN, PAUL DALGLISH, BRAD SPARKES, and ROBERT SCHAEFER, Defendants. NOTICE OF PENDENCY AND PROPOSED SETTLEMENT OF STOCKHOLDER CLASS ACTION, SETTLEMENT HEARING, AND RIGHT TO APPEAR The Delaware Court of Chancery authorized this Notice. This is not a solicitation from a lawyer. TO: ALL PERSONS WHO HELD SHARES OF NORTHERN GENESIS ACQUISITION CORP (“NGA” OR THE “COMPANY”) CLASS A COMMON STOCK, WHO HELD SUCH STOCK AS OF APRIL 21, 2021 (THE “REDEMPTION DEADLINE”), EITHER OF RECORD OR BENEFICIALLY, AND WHO ELECTED NOT TO REDEEM ALL OF SUCH SHARES, INCLUDING THEIR SUCCESSORS-IN-INTEREST WHO OBTAINED THEIR SHARES BY OPERATION OF LAW, BUT EXCLUDING: (I) DEFENDANTS, AS WELL AS THE MEMBERS OF THEIR IMMEDIATE FAMILIES; (II) ANY PERSON, FIRM, TRUST, CORPORATION, OR ANY ENTITY RELATED TO OR AFFILIATED WITH ANY OF THE FOREGOING INDIVIDUALS, OR IN WHICH ANY OF THE FOREGOING INDIVIDUALS OR ENTITIES HAS A CONTROLLING INTEREST; AND (III) THE LEGAL REPRESENTATIVES, HEIRS, SUCCESSORS, OR ASSIGNEES OF Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1- 855-961-0957 ANY SUCH EXCLUDED PERSONS —IN EACH CASE, ONLY TO THE EXTENT SUCH PERSONS OR ENTITIES HELD SHARES OF NGA CLASS A COMMON STOCK AS OF THE REDEMPTION DEADLINE (THE “CLASS”). EXCLUDED PERSONS ALSO INCLUDE ANY TRUSTS, ESTATES, ENTITIES, OR ACCOUNTS THAT HELD SHARES OF NGA CLASS A COMMON STOCK FOR THE BENEFIT OF ANY EXCLUDED PERSONS. 1 NOTICE OF PENDENCY OF CLASS ACTION: Please be advised that your rights will be affected by the above-captioned stockholder class action (the “Action”) pending in the Court of Chancery of the State of Delaware (the “Court”) if you held shares of NGA Class A common stock on the Redemption Deadline and elected not to redeem all of those shares. NOTICE OF SETTLEMENT: Please also be advised that (i) plaintiffs Ahuva Schachter, Michael Smith, Douglas Neujahr, Samhita Gera, and Denish Bhavsar (together, “Plaintiffs”), on behalf of themselves and all other members of the Class (as defined herein); and (ii) defendants Ian Robertson (“Robertson”), Ken Manget (“Manget”), Christopher Jarratt (“Jarratt”), Michael Hoffman (“Hoffman”), Paul Dalglish (“Dalglish”), Brad Sparkes (“Sparkes”), and Robert Schaefer (“Schaefer”) (together, “Defendants,” and Plaintiffs and Defendants together, the “Parties”), have reached a proposed settlement for $4 million in cash as set forth in the Stipulation (the “Settlement”). The proposed Settlement, if approved by the Court, will resolve all claims in the Action as against the Defendants. PLEASE READ THIS NOTICE CAREFULLY AND IN ITS ENTIRETY. This Notice explains how Class Members will be affected by the Settlement. The following table provides a brief summary of the rights you have as a Class Member and the relevant deadlines, which are described in more detail later in this Notice. 1 Any capitalized terms used in this Notice that are not otherwise defined in this Notice shall have the meanings given to them in the Stipulation and Agreement of Compromise, Settlement, and Release between the Parties, dated August 26, 2026 (the “Stipulation”). A copy of the Stipulation is available at www.LionElectricStockholdersLitigation.com. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 2 CLASS MEMBERS’ LEGAL RIGHTS IN THE SETTLEMENT: TO RECEIVE A If you are a member of the Class, you may be eligible PAYMENT FROM THE to receive a distribution from the Settlement proceeds. SETTLEMENT, CLASS Class Members must submit a Proof of Claim and MEMBERS MUST Release in order to receive a distribution from the SUBMIT A PROOF OF Settlement, if approved by the Court. If you are CLAIM AND RELEASE eligible to receive a distribution from the Settlement, POSTMARKED (IF it will be paid to you directly. See paragraphs 56-74 MAILED), OR ONLINE, below for further discussion. NO LATER THAN JANUARY 30, 2027. OBJECT TO THE If you are a member of the Class and would like to SETTLEMENT BY object to the proposed Settlement, the proposed Plan SUBMITTING A of Allocation, or Plaintiffs’ Counsel’s2 application for WRITTEN OBJECTION an award of attorneys’ fees and expenses, including SO THAT IT IS Plaintiffs’ application for Incentive Awards, you may RECEIVED NO LATER write to the Court and explain the reasons for your THAN NOVEMBER 13, objection. 2026. ATTEND A HEARING Filing a written objection and notice of intention to ON DECEMBER 1, 2026, appear that is received by November 13, 2026, allows AT 11:00 A.M., AND you to speak in Court, at the discretion of the Court, FILE A NOTICE OF about your objection. In the Court’s discretion, the INTENTION TO December 1, 2026 hearing may be conducted by APPEAR SO THAT IT IS telephone or videoconference (see Paragraphs 82-84 RECEIVED NO LATER below). If you submit a written objection, you may THAN NOVEMBER 13, (but you do not have to) attend the hearing and, at the 2026. discretion of the Court, speak to the Court about your objection. 2 “Plaintiffs’ Counsel” are Plaintiffs’ Lead Counsel: Grant & Eisenhofer P.A., Robbins Geller Rudman & Dowd LLP, and Robbins LLP. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 3 CLASS MEMBERS’ LEGAL RIGHTS IN THE SETTLEMENT: DO NOTHING. If you are a member of the Class and you do not submit a valid Proof of Claim and Release, you will not be eligible to receive any payment from the Settlement Fund. You will, however, remain a member of the Class, which means that you give up your right to sue about the claims that are resolved by the Settlement and you will be bound by any judgments or orders entered by the Court in the Action. In short, if you are a Class Member and do not submit a valid Proof of Claim and Release, you will still release all claims related to this Action, as detailed in paragraph 52 below. WHAT THIS NOTICE CONTAINS WHAT IS THE PURPOSE OF THIS NOTICE? .................................................5 WHAT IS THIS CASE ABOUT?........................................................................... 6 HOW DO I KNOW IF I AM AFFECTED BY THE SETTLEMENT? ........... 10 WHAT ARE THE TERMS OF THE SETTLEMENT? .................................... 11 WHAT ARE THE PARTIES’ REASONS FOR THE SETTLEMENT?......... 12 HOW DO I PARTICIPATE IN THE SETTLEMENT? WHAT DO I NEED TO DO? ................................................................................................................... 13 HOW MUCH WILL MY PAYMENT FROM THE SETTLEMENT, IF ANY, BE? .........................................................................................................................14 PROPOSED PLAN OF ALLOCATION .............................................................14 CALCULATION OF LOSS AMOUNTS ............................................................15 ADDITIONAL PROVISIONS..............................................................................17 WHAT WILL HAPPEN IF THE SETTLEMENT IS APPROVED? WHAT CLAIMS WILL THE SETTLEMENT RELEASE? .......................................... 19 HOW WILL PLAINTIFFS’ COUNSEL BE PAID? .......................................... 22 Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 4 WHEN AND WHERE WILL THE SETTLEMENT HEARING BE HELD? DO I HAVE TO ATTEND THE HEARING? MAY I SPEAK AT THE HEARING IF I DON’T LIKE THE SETTLEMENT? ...................................... 22 CAN I SEE THE COURT FILE? WHOM SHOULD I CONTACT IF I HAVE QUESTIONS? ............................................................................................ 26 WHAT IF I HELD SHARES ON SOMEONE ELSE’S BEHALF? ................. 26 WHAT IS THE PURPOSE OF THIS NOTICE? 1. The purpose of this Notice is to notify Class Members of the existence of the Action and the terms of the proposed Settlement. The Notice is also being sent to inform Class Members of a hearing that the Court has scheduled to consider the fairness, reasonableness, and adequacy of the Settlement, the proposed Plan of Allocation for the Settlement proceeds, and the application by Plaintiffs’ Counsel for an award of attorneys’ fees and expenses, including Plaintiffs’ application for Incentive Awards (the “Settlement Hearing”). See paragraphs 82-84 below for details about the Settlement Hearing, including the date and time of the hearing. 2. The Court directed that this Notice be mailed to you because you may be a member of the Class. The Court has directed us to send you this Notice because, as a Class Member, you have a right to know about your options before the Court rules on the proposed Settlement. Additionally, you have the right to understand how the Action and the proposed Settlement generally affect your legal rights. Please Note: The Court may approve the proposed Settlement with such modifications as the Parties may agree to, if appropriate, without further notice to the Class. 3. The issuance of this Notice is not an expression by the Court of any findings of fact or any opinion concerning the merits of any claim in the Action, and the Court has not yet decided whether to approve the Settlement. If the Court approves the Settlement, then payments to Authorized Claimants (see paragraphs 56-74 below) will be made after any appeals are resolved. PLEASE NOTE: Receipt of this Notice does not mean that you are a Class Member or an Authorized Claimant or that you will be entitled to receive a payment from the Settlement. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 5 WHAT IS THIS CASE ABOUT? THE FOLLOWING RECITATION DOES NOT CONSTITUTE FINDINGS OF THE COURT. THE COURT HAS MADE NO FINDINGS WITH RESPECT TO THE FOLLOWING MATTERS, AND THESE RECITATIONS SHOULD NOT BE UNDERSTOOD AS AN EXPRESSION OF ANY OPINION OF THE COURT AS TO THE MERITS OF ANY OF THE CLAIMS OR DEFENSES RAISED BY ANY OF THE PARTIES. 4. On May 27, 2020, NGA was incorporated in Delaware for the purpose of effecting a merger, capital stock exchange, asset acquisition, stock purchase, reorganization, or similar business combination with one or more businesses. 5. On August 20, 2020, NGA completed its initial public offering of 30,000,000 million units, with each unit consisting of one share of NGA Class A common stock and one-half of one redeemable warrant. Simultaneously with the IPO, NGA sold 7,750,000 Private Placement Warrants to Northern Genesis Sponsor, LLC at a price of $1 per warrant. 6. On or around August 27, 2020, the underwriters partially exercised an overallotment, with NGA selling an additional 1,945,344 units and 389,069 Private Placement Warrants. 7. On November 29, 2020, NGA entered into a business combination agreement with The Lion Electric Company and its wholly owned subsidiary, Lion Electric Merger Sub Inc. (together, “Legacy Lion Electric”), pursuant to which NGA would merge with a reorganized Legacy Lion Electric (the “Merger”) to form a publicly traded entity, The Lion Electric Company (“New Lion Electric”). NGA and Legacy Lion Electric announced the Merger on November 30, 2020. 8. On March 24, 2021, NGA filed with the U.S. Securities and Exchange Commission a proxy statement concerning the Merger (such proxy statement together with any preliminary proxy filings, as well as any amendments or supplements thereto, the “Proxy”), which was disseminated to NGA stockholders. The Proxy informed stockholders of a special meeting to be held on April 23, 2021 (the “Special Meeting”), at which, among other things, stockholders would vote whether to approve the Merger and related transactions. The Proxy also informed stockholders that the deadline for them to redeem their shares in connection with the Merger was April 21, 2021 – two business days before the Special Meeting (the “Redemption Deadline”). Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 6 9. On April 23, 2021, NGA stockholders voted to approve the Merger at the Special Meeting. 10. On May 6, 2021, the Merger closed. Following the Merger’s closing, New Lion Electric securities (common shares and warrants) began trading on the New York Stock Exchange and the Toronto Stock Exchange. 11. On November 1, 2023, Plaintiffs commenced this Action against the Defendants on behalf of themselves and all other similarly situated former NGA stockholders by filing a Verified Class Action Complaint (the “Complaint”), asserting, among other things, claims against the Defendants for breach of fiduciary duty and unjust enrichment resulting from the alleged impairment of NGA stockholders’ redemption rights in connection with the Merger. 12. On February 9, 2024, Defendants filed a motion and opening brief seeking to dismiss the Complaint. 13. On March 11, 2024, Plaintiffs filed a Verified Amended Class Action Complaint (the “Amended Complaint”), adding more detail to the existing claims against the Defendants, and asserting additional claims against New Lion Electric, Marc Bedard and Nicolas Brunet (“collectively, the “Former Defendants”) for aiding and abetting Defendants’ breaches of fiduciary duty. 14. On March 25, 2024, Defendants filed a motion to dismiss the Amended Complaint. On April 25, 2024, Defendants and the Former Defendants jointly filed an Amended Motion to Dismiss the Amended Complaint and opening brief (“Motion to Dismiss”). 15. On September 18, 2024, following briefing on the Motion to Dismiss by the Parties, the Court held oral argument. Following oral argument, the Court took the Motion to Dismiss under advisement and requested supplemental briefing on the issue of standing to enforce the Merger’s forum selection clause against the Former Defendants. On December 18, 2024, the Parties completed the supplemental briefings. 16. On December 17, 2024, New Lion Electric initiated voluntary restructuring proceedings (the “Canadian Proceeding”) before the Superior Court of Québec (Commercial Division) (the “Canadian Court”) pursuant to the Companies’ Creditors Arrangement Act, R.S.C. 1985, c. C-36. 17. On December 18, 2024, New Lion Electric commenced Chapter 15 cases in the United States Bankruptcy Court for the Northern District of Illinois Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 7 Eastern Division (“Bankruptcy Court”), seeking recognition of the Canadian Proceeding and any orders entered by the Canadian Court. 18. On January 21, 2025, the Bankruptcy Court entered an order, which, among other things, granted New Lion Electric the application of the protection afforded by the automatic stay under Section 362(a) of the Bankruptcy Code. 19. On January 23, 2025, while the Motion to Dismiss was sub judice before the Court, Defendants and the Former Defendants filed a Suggestion of Bankruptcy and Automatic Stay of Proceedings, informing the Court of the restructuring proceedings and automatic stay. 20. On May 15, 2025, Plaintiffs filed a Motion to Proceed with Claims Against Non-Debtor Defendants (“Motion to Proceed”), seeking to proceed with their claims against Defendants and the Former Defendants other than New Lion Electric. 21. On May 22, 2025, the Canadian Court entered an Approval and Reverse Vesting Order (the “RVO”) that, among other things, released New Lion Electric from any and all liabilities, obligations, or causes of action relating to the Excluded Liabilities (as defined in the RVO). The RVO also contained a partial release of claims in favor of current and former directors of the Debtors, including New Lion Electric and NGA (the “D&O Release”). The Canadian Court temporarily carved out Plaintiffs’ claims in this Action from the approved D&O Release pending a later hearing. 22. On August 11, 2025, the Parties filed a Stipulation and [Proposed] Order of Voluntary Dismissal Without Prejudice of the Lion Electric Company, which was granted by the Court on August 12, 2025. 23. On August 18, 2025, the Court entered an order granting Plaintiffs’ Motion to Proceed with Claims Against Non-Debtor Defendants. 24. On August 19, 2025, the Parties filed, and the Court granted, a Stipulation and [Proposed] Order to Dismiss Defendants Marc Bedard and Nicolas Brunet Pursuant to Rule 41(a)(1)(ii). 25. On August 27, 2025, Plaintiffs submitted a letter to the Canadian Court, objecting to and arguing against the Debtors’ request for entry of an amended RVO with a full D&O Release that would, among other things, release Plaintiffs’ claims against Defendants. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 8 26. On September 2, 2025, the Court took under advisement what remained of the pending Motion to Dismiss. 27. On or about September 2, 2025, Plaintiffs retained counsel in Canada to represent their interests and submit a formal Notice of Objection in the Canadian Proceeding. On September 3-4, 2025, the Canadian Court held a two-day hearing in connection with the scope of D&O Release sought by the Debtors. 28. On November 17, 2025, the Canadian Court granted Plaintiffs’ Notice of Objection and entered a Re-Rectified RVO with a D&O Release that specially excluded Plaintiffs’ claims in this Action. On December 5, 2025, the Debtors in the Canadian Proceeding filed a Motion for Leave to Appeal the Canadian Court’s decision. 29. On December 18, 2025, the Court ruled on the Motion to Dismiss by granting it in part and denying in part. The Court sustained Plaintiffs’ claims for (i) breach of fiduciary duty against Robertson, Manget, Dalglish, Schaefer, and Sparkes in their capacities as NGA directors, (ii) breach of fiduciary duty against Robertson, Hoffman, and Manget in their capacities as NGA officers, (iii) breach of fiduciary duty against Robertson and Jarratt in their capacities as controllers of NGA, and (iv) unjust enrichment against Robertson, Jarratt, Manget, Hoffman, Dalglish, Sparkes, and Schaefer. The Court dismissed Plaintiffs’ claims against the Former Defendants based on the prior stipulations and orders to dismiss the Former Defendants. 30. On January 22, 2026, Plaintiffs served the First Request for Production of Documents Directed to the Defendants (“Plaintiffs’ First RFPs”). 31. On January 27, 2026, the Parties filed a Stipulation and [Proposed] Order Governing Case Schedule, which was granted by the Court on January 28, 2026. 32. On February 9, 2026, Defendants filed an Answer to the Amended Complaint. 33. On February 12, 2026, the Court of Appeal of Quebec (Montreal) granted Debtors’ Motion for Leave to Appeal the Canadian Court’s decision concerning the scope of D&O Release. 34. On February 17, 2026, Defendants served their Responses and Objections to Plaintiffs’ First RFPs. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 9 35. On March 10, 2026, Defendants served their First Set of Requests for Production of Documents to Plaintiffs (“Defendants’ First RFPs”). 36. On March 17, 2026, the Parties filed, and the Court granted, a Stipulation and [Proposed] Order for the Production and Exchange of Confidential Information. 37. On March 25, 2026, following a meet and confer with Plaintiffs, Defendants served their Amended Responses and Objections to Plaintiffs’ First RFPs. 38. On March 18, 2026, Defendants made an initial production of forty documents, consisting of 190 pages. 39. On March 31, 2026, the Parties filed, and the Court granted, a Stipulation and [Proposed] Order Governing Expert Discovery. 40. On April 9, 2026, Plaintiffs served their Responses and Objections to the Defendants’ First RFPs. 41. On April 28, 2026, the Parties reached an agreement in principle to settle the Action. 42. On September 14, 2026, the Court entered a Scheduling Order directing that notice of the Settlement be provided to potential Class Members, and scheduling the Settlement Hearing to, among other things, consider whether to grant final approval to the Settlement. HOW DO I KNOW IF I AM AFFECTED BY THE SETTLEMENT? 43. If you are a member of the Class, you are subject to the Settlement. The non-opt-out Class preliminarily certified by the Court solely for purposes of the Settlement, pursuant to Rule 23 of the Court of Chancery of the State of Delaware, consists of: all record and beneficial holders of NGA Class A Common Stock, who held such shares as of the Redemption Deadline and who elected not to redeem all such shares, including their successors-in- interest who obtained shares by operation of law, but excluding the Excluded Persons. Excluded Persons are (i) Defendants and the members of Defendants’ immediate families; (ii) any Person, firm, Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 10 trust, corporation, or any entity related to or affiliated with any of the foregoing individuals, or in which any of the foregoing individuals or entities has a controlling interest; and (iii) the legal representatives, heirs, successors, or assignees of any such Excluded Persons —in each case, only to the extent such Persons or entities held shares of NGA Class A Common Stock as of the Redemption Deadline. Excluded Persons also include any trusts, estates, entities, or accounts that held shares of NGA Class A Common Stock for the benefit of any Excluded Persons. PLEASE NOTE: The Class is a non-“opt-out” class pursuant to Delaware Court of Chancery Rules 23(a) and 23(b)(1). Accordingly, Class Members do not have the right to exclude themselves from the Class. Also, receipt of this Notice does not mean that you are a Class Member or that you will be entitled to a payment from the Settlement. If you are a Class Member and you wish to be eligible to receive a payment from the Settlement, you are required to submit a Proof of Claim and Release and the required supporting documentation as set forth in the Proof of Claim and Release postmarked (if mailed), or online at www.LionElectricStockholdersLitigation.com, no later than January 30, 2027. WHAT ARE THE TERMS OF THE SETTLEMENT? 44. In consideration of the settlement of the Released Plaintiffs’ Claims (defined in paragraph 76 below) against Defendants and the other Released Defendant Parties (defined in paragraph 76 below), the Defendants shall pay or cause to be paid the Settlement Amount ($4,000,000.00) into an interest-bearing escrow account (the “Escrow Account”) for the benefit of the Class. Defendants will cause the Settlement Amount to be deposited into the Escrow Account within twenty (20) business days after entry of the Scheduling Order by the Court. 45. The Settlement Amount plus any and all interest earned thereon is referred to as the “Settlement Fund.” The Settlement Fund less: (i) any Taxes; (ii) any Notice and Administration Costs; (iii) any Court-awarded attorneys’ fees and/or litigation expenses to Plaintiffs’ Counsel to be paid from the Settlement Fund, including any incentive awards to Plaintiffs to be deducted solely from any award of attorneys’ fees to Plaintiffs’ Counsel; and (iv) any other costs or fees approved by the Court, is referred to as the “Net Settlement Fund.” See paragraphs 56-74 below for details about the distribution of the Net Settlement Fund to Class Members (defined in paragraph 43 above). Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 11 46. Defendants shall bear no personal responsibility for any payment in connection with the Stipulation. WHAT ARE THE PARTIES’ REASONS FOR THE SETTLEMENT? 47. Plaintiffs, through Plaintiffs’ Lead Counsel, conducted an investigation relating to the claims and the underlying events alleged in the Action. Plaintiffs’ Lead Counsel have analyzed the evidence adduced during the investigation and discovery as described above and have also researched the applicable law with respect to the claims asserted in the Action and the potential defenses thereto. This investigation and the settlement negotiations between the Parties have provided Plaintiffs with a detailed basis upon which to assess the relative strengths and weaknesses of Plaintiffs’ position with respect to the Defendants and Defendants’ positions in the Action. 48. Based upon their investigation, prosecution, and mediation of the Action, Plaintiffs and Plaintiffs’ Lead Counsel have concluded that while they believe that the claims they asserted have merit, the significant risks and uncertainties of further litigation outweigh the potential for recovery. In addition to the benefits of the Settlement for the Class, Plaintiffs and Plaintiffs’ Lead Counsel have considered: (i) the attendant risks of continued litigation and the uncertainty of the outcome of the Action; (ii) the probability of success on the merits; (iii) the inherent hurdle of proving liability and damages associated with, and the strength of defenses to, the claims asserted in the Action, which depend in part on theories of liability that have not been addressed by the Delaware Supreme Court; (iv) the desirability of permitting the Settlement to be consummated according to its terms; (v) the expense and length of continued proceedings necessary to prosecute the Action through trial and appeals; and (vi) the conclusion of Plaintiffs and Plaintiffs’ Lead Counsel that the terms and conditions of the Settlement and the Stipulation are fair, reasonable, and adequate, and that it is in the best interests of the Class to settle the claims asserted in the Action on the terms set forth therein. The Settlement and the Stipulation shall in no event be construed as, or deemed to be, evidence of a concession by Plaintiffs of any infirmity in the claims asserted in the Action. 49. Based on Plaintiffs’ Lead Counsel’s thorough review and analysis of the relevant facts, allegations, defenses, and controlling legal principles, Plaintiffs’ Counsel believe that the Settlement set forth in the Stipulation is fair, reasonable, and adequate, and confers substantial benefits upon the Class. Based upon their direct oversight of the prosecution of this Action, as well as evaluation and input Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 12 from Plaintiffs’ Lead Counsel, Plaintiffs have determined that the Settlement is in the best interests of the Class and have agreed to the terms and conditions set forth in the Stipulation. 50. Defendants deny all allegations of wrongdoing, fault, liability, or damage to Plaintiffs and the Class, and further deny that Plaintiffs have asserted a valid claim as to either of them. Defendants further deny that they engaged in any wrongdoing or committed, or aided or abetted, any violation of law or breach of duty and believe that at all relevant times they acted properly, in good faith, and in a manner consistent with their legal duties and are entering into the Settlement and the Stipulation solely to avoid the substantial burden, expense, inconvenience, and distraction of continued litigation and to resolve each of Plaintiffs’ claims against Defendants. The Settlement and the Stipulation shall in no event be construed as, or deemed to be, evidence of or an admission or concession on the part of the Defendants with respect to any claim or factual allegation or of any fault or liability or wrongdoing or damage whatsoever or any infirmity in the defenses that Defendants have or could have asserted. HOW DO I PARTICIPATE IN THE SETTLEMENT? WHAT DO I NEED TO DO? 51. To be eligible for a payment from the Settlement, you must be a member of the Class and you must timely complete and return a Proof of Claim and Release with adequate supporting documentation postmarked (if mailed), or submitted online at www.LionElectricStockholdersLitigation.com, no later than January 30, 2027. A Proof of Claim and Release is included with this Notice, or you may obtain a copy from the Settlement website maintained by the Settlement Administrator, www.LionElectricStockholdersLitigation.com, or you may request that a Proof of Claim and Release be mailed to you by calling the Settlement Administrator toll-free at 1-855-961-0957, or by emailing the Settlement Administrator at info@LionElectricStockholdersLitigation.com. Please retain all records of your ownership of and transactions in NGA and/or New Lion Electric common stock, as they may be needed to document your Claim. The Parties and Settlement Administrator do not have information about your transactions in NGA and/or New Lion Electric common stock. 52. Class Members who do not timely submit a valid Proof of Claim and Release will not be entitled to any distributions from the Net Settlement Fund, but will otherwise be bound by the Settlement. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 13 HOW MUCH WILL MY PAYMENT FROM THE SETTLEMENT, IF ANY, BE? 53. PLEASE NOTE: As stated above, the Settlement Amount will be deposited into an interest-bearing escrow account for the benefit of the Class. If the Settlement is approved by the Court and the Effective Date of the Settlement occurs, the Net Settlement Fund (that is, the Settlement Amount plus any interest accrued thereon after its deposit in the Escrow Account less: (i) any Taxes or Tax Expenses, (ii) any Notice and Administration Costs, (iii) any Fee and Expense Award awarded by the Court, and (iv) any other costs or fees approved by the Court) will be distributed in accordance with the proposed Plan of Allocation stated below or such other plan of allocation as the Court may approve. 54. The Net Settlement Fund will not be distributed unless and until the Court has approved the Settlement and a plan of allocation, and the time for any petition for rehearing, appeal, or review, whether by certiorari or otherwise, has expired. Approval of the Settlement is independent from approval of a plan of allocation. Any determination with respect to a plan of allocation will not affect the Settlement, if approved. 55. The Court may approve the Plan of Allocation as proposed or it may modify the Plan of Allocation without further notice to the Class. Any Orders regarding any modification of the Plan of Allocation will be posted on the Settlement website, www.LionElectricStockholdersLitigation.com. PROPOSED PLAN OF ALLOCATION 56. If the Settlement is approved by the Court, the Net Settlement Fund will be distributed only to Class Members who or which submit a valid “Proof of Claim and Release” (attached hereto) to the Settlement Administrator that is approved by the Court for payment from the Net Settlement Fund (the “Authorized Claimants”) in accordance with this proposed Plan of Allocation (“Plan of Allocation” or “Plan”) or such other plan of allocation as the Court may approve. Class Members who or which do not timely submit a valid Proof of Claim and Release will not share in the Net Settlement Fund but will otherwise be bound by the Settlement. The Court may approve this proposed Plan of Allocation, or modify it, without additional notice to the Class. Any order modifying the Plan of Allocation will be posted on the Settlement website, www.LionElectricStockholdersLitigation.com. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 14 57. The objective of the Plan of Allocation is to distribute the Net Settlement Fund equitably among Class Members. The Plan of Allocation is not a formal damages analysis, and the calculations made in accordance with the Plan of Allocation are not intended to be estimates of, or indicative of, the amounts that Class Members might have been able to recover after a trial. Nor are the calculations in accordance with the Plan of Allocation intended to be estimates of the amounts that will be paid to Authorized Claimants under the Settlement. The computations under the Plan of Allocation are only a method to weigh, in a fair and equitable manner, the claims of Authorized Claimants against one another for the purpose of making pro rata allocations of the Net Settlement Fund. The formulas below are intended solely for purposes of this Plan of Allocation and cannot and should not be binding on Plaintiffs or any Class Member for any other purpose. CALCULATION OF LOSS AMOUNTS 58. Based on the formulas set forth below, a “Loss Amount” will be calculated for each share of NGA Class A common stock held by an Authorized Claimant as of the Redemption Deadline, i.e., the close of trading on April 21, 2021, and for which adequate documentation is provided to the Settlement Administrator (each such share being an “Eligible Share”). Following the closing of the Merger on May 6, 2021, shares of NGA Class A common stock converted to New Lion Electric common stock. For the avoidance of doubt, there will be no Loss Amount for (i) any Redeemed Shares, i.e., shares of NGA Class A common stock redeemed before the Merger; or (ii) any Founder Shares. 59. Based on the above, a Loss Amount will be calculated for each Eligible Share as follows: (i) The Loss Amount for each Eligible Share of NGA common stock sold after the Redemption Deadline and prior to the close of trading on May 6, 2021 (the date the Merger closed), at a price below $10.00 (the “Redemption Price”) shall be the Redemption Price of $10.00 minus the sale price, plus the Nominal Amount (as defined below). (ii) The Loss Amount for each Eligible Share of NGA common stock sold after the Redemption Deadline and prior to the close of trading on May 6, 2021 (the date the Merger closed), at a price of $10.00 or greater shall be zero, plus the Nominal Amount (as defined below). (iii) The Loss Amount for each Eligible Share converted to New Lion Electric common stock and sold after the close of trading on May 6, 2021 (the date Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 15 the Merger closed), and prior to the close of trading on November 1, 2023 (the date the Complaint was filed), at a price below $10.00, shall be the Redemption Price of $10.00 minus the sale price, plus the Nominal Amount (as defined below). (iv) The Loss Amount for each Eligible Share converted to New Lion Electric common stock and sold after the close of trading on May 6, 2021 (the date the Merger closed), and prior to the close of trading on November 1, 2023 (the date the Complaint was filed), at a price of $10.00 or greater shall be zero, plus the Nominal Amount (as defined below). (v) The Loss Amount for each Eligible Share converted to New Lion Electric common stock and held as of the close of trading on November 1, 2023 (the date the Complaint was filed), shall be $8.47 per share, calculated as the Redemption Price of $10.00 minus $1.53 (the closing stock price of Lion Electric common stock on November 1, 2023, rounded to the cent), plus the Nominal Amount (as defined below). (vi) The Nominal Amount shall be $0.10 per share for each Eligible Share. A Claimant’s “Recognized Claim” will be the sum of his, her, or its 60. Loss Amounts as calculated under paragraph 59 above. 61. For the avoidance of doubt, there will be no Loss Amount calculated for any share of NGA Class A common stock redeemed in connection with the Merger. To the extent that the calculation of an Authorized Claimant’s Total Loss results in a negative number, that number shall be set to zero. 62. The Net Settlement Fund will be distributed to all Authorized Claimants on a pro rata basis based on the relative size of the Authorized Claimant’s Recognized Claim. Specifically, a “Claimed Distribution Amount” will be calculated for each Authorized Claimant, which will be the sum of the Authorized Claimant’s Recognized Claim divided by the combined Recognized Claims for all Authorized Claimants, multiplied by the total amount in the Net Settlement Fund. If the Authorized Claimant’s Claimed Distribution Amount calculates to less than $10.00, it will not be included in the calculation, and no distribution will be made to that Authorized Claimant; however, they will nevertheless be bound by the Settlement and the Order and Final Judgment of the Court dismissing this Action. 63. If the sum total of Recognized Claims of all Authorized Claimants who are entitled to receive payment out of the Net Settlement Fund is greater than the Net Settlement Fund, each Authorized Claimant shall receive their pro rata share of the Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 16 Net Settlement Fund. If the Net Settlement Fund exceeds the sum total of Recognized Claims of all Authorized Claimants entitled to receive payment out of the Net Settlement Fund, the excess amount in the Net Settlement Fund shall be distributed pro rata to all Authorized Claimants entitled to receive payment. Defendants shall not have a reversionary interest in the Net Settlement Fund. ADDITIONAL PROVISIONS 64. Any transaction in common stock executed outside regular trading hours for the U.S. financial market shall be deemed to have occurred during the next trading session. 65. All purchases, acquisitions, and sales shall exclude any fees, taxes, and commissions. 66. If an Authorized Claimant has more than one purchase (or acquisition) and sale of NGA or Lion Electric shares, all such purchases and sales shall be matched on a First-In, First-Out (“FIFO”) basis. Sales will be matched against purchases in chronological order, beginning with the earliest purchase made. 67. Purchases, acquisitions, and sales of Eligible Shares shall be deemed to have occurred on the “contract” or “trade” date as opposed to the “settlement” or “payment” date. The receipt or grant by gift, inheritance, or operation of law of Eligible Shares shall not be deemed a purchase, acquisition, or sale of these Eligible Shares for the calculation of Loss Amount, nor shall the receipt or grant be deemed an assignment of any claim relating to the purchase/acquisition of such Eligible Shares unless: (i) the donor or decedent purchased or otherwise acquired such Eligible Shares; (ii) no Proof of Claim was submitted by or on behalf of the donor, on behalf of the decedent, or by anyone else with respect to such Eligible Shares; and (iii) it is specifically so provided in the instrument of gift or assignment. 68. The date of covering a “short sale” is deemed to be the date of purchase or acquisition of Eligible Shares. The date of a “short sale” is deemed to be the date of sale of the Eligible Shares. Under the Plan of Allocation, however, the Loss Amount on “short sales” is zero and the Loss Amount on any portion of a purchase or acquisition that matches against (or “covers”) a “short sale” is zero. The Loss Amount on a “short sale” that is not covered by a purchase or acquisition is also zero. 69. The Eligible Shares are the only security eligible for recovery under the Plan of Allocation. Option contracts are not securities eligible to participate in the Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 17 Settlement. With respect to Eligible Shares purchased or sold through the exercise of an option, the purchase/sale date of the Eligible Shares is the exercise date of the option and the purchase/sale price of the Eligible Shares is the exercise price of the option. 70. Distributions will be made to Authorized Claimants pursuant to this Plan of Allocation after all claims have been processed and after the Court has finally approved the Settlement. 71. After the initial distribution of the Net Settlement Fund, the Settlement Administrator will make reasonable and diligent efforts to have Authorized Claimants cash their distribution checks. To the extent any monies remain in the Net Settlement Fund one hundred eighty (180) days after the initial distribution, if Plaintiffs’ Lead Counsel, in consultation with the Settlement Administrator, determine that it is cost-effective to do so, the Settlement Administrator will conduct a redistribution of the funds remaining after payment of any unpaid fees and expenses incurred in administering the Settlement, including for such redistribution, to Authorized Claimants who have cashed their initial distributions and who would receive at least $10.00 from such redistribution. Additional redistributions to Authorized Claimants who have cashed their prior checks may occur thereafter if Plaintiffs’ Lead Counsel, in consultation with the Settlement Administrator, determine that additional redistributions, after the deduction of any additional fees and expenses incurred in administering the Settlement, including for such redistributions, would be cost-effective. At such time as it is determined that the redistribution of funds remaining in the Net Settlement Fund is not cost-effective, the remaining balance will be contributed to the Combined Campaign for Justice, P.O. Box 2113, Wilmington, Delaware 19899, a 501(c)(3) charitable organization. 72. Payment pursuant to the Plan of Allocation or such other plan as may be approved by the Court for this Settlement shall be conclusive against all Class Members. No person shall have any claim against Plaintiffs, Plaintiffs’ Counsel, any Plaintiffs’ expert, Defendants or Released Defendant Parties, Defendants’ Counsel, any of the other Class Members, or the Settlement Administrator or other agent designated by Plaintiffs’ Counsel, arising from distributions made substantially in accordance with the Stipulation, the plan of allocation approved by the Court, or further orders of the Court. Plaintiffs, Plaintiffs’ Counsel, Defendants, Defendants’ Counsel, and all other Released Parties shall have no responsibility for or liability whatsoever for the investment or distribution of the Settlement Fund or the Net Settlement Fund; the Plan of Allocation; the determination, administration, calculation, or payment of any Proof of Claim or nonperformance of the Settlement Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 18 Administrator; the payment or withholding of Taxes; or any losses incurred in connection therewith. 73. The Court has reserved jurisdiction to allow, disallow, or adjust on equitable grounds the claim of any Class Member or claimant. 74. Each claimant shall be deemed to have submitted to the jurisdiction of the Court with respect to his, her, or its Proof of Claim. WHAT WILL HAPPEN IF THE SETTLEMENT IS APPROVED? WHAT CLAIMS WILL THE SETTLEMENT RELEASE? 75. If the Settlement is approved, the Court will enter a Final Order and Judgment (the “Judgment”). Pursuant to the Judgment, the claims asserted against Defendants in the Action will be dismissed with prejudice, and the following releases will occur: (i) Upon the Effective Date, Released Plaintiffs Parties shall be deemed to have, and by operation of law and of the Judgment shall have, fully, finally, and forever compromised, settled, released, resolved, relinquished, waived, discharged, and dismissed with prejudice any and all Released Plaintiffs’ Claims (as defined below) against Defendants and the other Released Defendant Parties (as defined below), and shall forever be barred and enjoined from commencing, instituting, instigating, facilitating, asserting, maintaining, participating in, or prosecuting any and all Released Plaintiffs’ Claims against any of the Released Defendant Parties. (ii) Upon the Effective Date, Released Defendant Parties shall have, fully, finally, and forever compromised, settled, released, resolved, relinquished, waived, discharged, and dismissed with prejudice any and all Released Defendants’ Claims (as defined below) against Plaintiffs and the other Released Plaintiffs Parties (as defined below), and shall forever be barred and enjoined from commencing, instituting, instigating, facilitating, asserting, maintaining, participating in, or prosecuting any and all Released Defendants’ Claims against any of the Released Plaintiffs Parties. 76. The following capitalized terms used in paragraph 75 above shall have the meanings specified below: “Released Claims” means, collectively, the Released Plaintiffs’ Claims and the Released Defendants’ Claims. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 19 “Released Plaintiffs’ Claims” means as against the Released Defendant Parties, to the fullest extent permitted by Delaware law, any and all manner of claims, including Unknown Claims, suits, actions, causes of action, demands, liabilities, losses, rights, obligations, duties, damages, diminution in value, disgorgement, debts, costs, expenses, interest, penalties, fines, sanctions, fees, attorneys’ fees, expert or consulting fees, agreements, judgments, decrees, matters, allegations, issues, and controversies of any kind, nature, or description whatsoever, whether known or unknown, disclosed or undisclosed, accrued or unaccrued, apparent or unapparent, foreseen or unforeseen, matured or unmatured, suspected or unsuspected, liquidated or unliquidated, fixed or contingent, whether based on state, local, federal, foreign, statutory, regulatory, or common law or equity or otherwise, that (i) were alleged, asserted, set forth, or claimed in the Complaint, or (ii) could have been alleged, asserted, set forth, or claimed in the Complaint, the Action, or in any other action in any other court, tribunal, proceeding, or other forum, by Plaintiffs or any other member of the Class, individually or on behalf of the Class that in full or in part, concern, are based upon, arise out of, relate to, or are in any way connected to the claims, allegations, transactions, facts, circumstances, events, acts, disclosures, statements, representations, omissions, or failures to act alleged, set forth, or referred to in the Complaint, arise out of, are based upon, relate to, or concern the rights of, duties owed to, and/or ownership of NGA Class A Common Stock as of the Redemption Deadline, the Proxy, any other disclosure relating to or concerning the Merger, or the involvement of any of the Released Defendant Parties with respect to any of the foregoing; provided, however, that the Released Plaintiffs’ Claims shall not include (a) any claims to enforce the Stipulation, or (b) any claims to enforce the Judgment entered by the Court. “Released Plaintiffs Parties” means Plaintiffs, all other Class Members, and Plaintiffs’ Counsel, and their legal representatives, heirs, executors, administrators, predecessors, successors, predecessors-in-interest, successors-in- interest, and assigns of any of the foregoing. “Released Defendants’ Claims” means as against the Released Plaintiffs Parties, any and all claims, complaints, causes of action, or sanctions, including Unknown Claims, that have been or could have been asserted by the Defendants in the Action, or in any court, tribunal, forum or proceeding, which arise out of or relate in any way to the institution, prosecution, settlement, or dismissal of the Action; provided, however, that the Released Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 20 Defendants’ Claims shall not include (i) any claims to enforce the Stipulation, or (ii) any claims to enforce the Judgment entered by the Court. “Released Defendant Parties” means Defendants and any and all of their respective employees, employers, controlling persons, affiliates, partners, representatives, attorneys, advisors, consultants, accountants, investment bankers, commercial bankers, agents, heirs, executors, trustees, personal representatives, estates, administrators, predecessors, successors, assigns, insurers, and reinsurers. “Unknown Claims” means Released Plaintiffs’ Claims and Released Defendants’ Claims that a releasing Person does not know or suspect to exist in his, her, or its favor at the time of the release, which if known by him, her, or it, might have affected his, her, or its decision(s) with respect to the Settlement. With respect to any and all Released Plaintiffs’ Claims and Released Defendants’ Claims, upon the Effective Date, Plaintiffs and the Defendants shall expressly waive, and each of the Released Plaintiffs Parties and Released Defendant Parties shall be deemed to have waived, and by operation of the Judgment shall have expressly waived, relinquished, and released any and all provisions, rights, and benefits conferred by any law of the United States or any state or territory of the United States or other jurisdiction, or principle of common law or foreign law, which is similar, comparable, or equivalent to Cal. Civ. Code § 1542, which provides: A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party. Plaintiffs and Defendants acknowledge, and each of the other Class Members shall be deemed by operation of law to have acknowledged, that the foregoing waiver was separately bargained for and a key element of the Settlement. 77. By Order of the Court, (i) Plaintiffs’ claims and proceedings against the Defendants, other than those proceedings necessary to carry out or enforce the terms and conditions of the Stipulation, have been stayed until otherwise ordered by the Court; and (ii) pending final determination of whether the Settlement should be approved, Plaintiffs and each of the other Class Members are barred and enjoined from commencing, instituting, instigating, facilitating, asserting, maintaining, Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 21 participating in, or prosecuting any and all Released Plaintiffs’ Claims against any of the Released Defendant Parties. HOW WILL PLAINTIFFS’ COUNSEL BE PAID? 78. Plaintiffs’ Counsel have not received any payment for their services in pursuing claims in the Action on behalf of the Class, nor have Plaintiffs’ Counsel been paid for their expenses incurred in connection with the Action. In connection with final approval of this Settlement, Plaintiffs’ Counsel intend to apply to the Court for a collective award of attorneys’ fees and litigation expenses (the “Fee and Expense Award”) to be paid solely from (and out of) the Settlement Fund, if the Settlement is approved by the Court. In connection with Plaintiffs’ Counsel’s application for a Fee and Expense Award (the “Fee and Expense Application”), Plaintiffs may petition the Court for incentive awards (the “Incentive Awards”) to be paid solely from any Fee and Expense Award to Plaintiffs’ Counsel. 79. The Fee and Expense Application will include a request for an award of attorneys’ fees not to exceed 20% of the Settlement Amount plus payment of litigation expenses incurred by Plaintiffs’ Counsel in connection with the Action through April 28, 2026. In connection with the Fee and Expense Application, each Plaintiff may petition the Court for an Incentive Award not to exceed $1,500.00 to be paid solely from any Fee and Expense Award to Plaintiffs’ Counsel. 80. The Court will determine the amount of any Fee and Expense Award to Plaintiffs’ Counsel and any Incentive Awards to Plaintiffs. Any Fee and Expense Award will be paid solely out of the Settlement Fund, and any Incentive Awards will be paid solely from any Fee and Expense Award. Class Members are not personally liable for any such fees or expenses. WHEN AND WHERE WILL THE SETTLEMENT HEARING BE HELD? DO I HAVE TO ATTEND THE HEARING? MAY I SPEAK AT THE HEARING IF I DON’T LIKE THE SETTLEMENT? 81. Class Members do not need to attend the Settlement Hearing. The Court will consider any submission made in accordance with the provisions below even if a Class Member does not attend the Settlement Hearing. Class Members can recover from the Settlement without attending the Settlement Hearing. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 22 82. Please Note: The date and time of the Settlement Hearing may change without further written notice to Class Members. In addition, the Court may decide to conduct the Settlement Hearing remotely by telephone or videoconference, or otherwise allow Class Members to appear at the hearing remotely by phone or video, without further written notice to Class Members. To determine whether the date and time of the Settlement Hearing have changed, or whether Class Members must or may participate remotely by phone or video, it is important that you monitor the Court’s docket and the Settlement website, www.LionElectricStockholdersLitigation.com, before making any plans to attend the Settlement Hearing. Any updates regarding the Settlement Hearing, including any changes to the date or time of the hearing, or updates regarding in-person or remote appearances at the hearing, will be posted to the Settlement website, www.LionElectricStockholdersLitigation.com. Also, if the Court requires or allows Class Members to participate in the Settlement Hearing remotely by telephone or videoconference, the information needed to access the conference will be posted to the Settlement website, www.LionElectricStockholdersLitigation.com. 83. Absent further order of the Court, the Settlement Hearing will be held on December 1, 2026, at 11:00 a.m., before The Honorable Nathan A. Cook, Vice Chancellor, at the Court of Chancery of the State of Delaware, New Castle County, Leonard L. Williams Justice Center, 500 North King Street, Wilmington, Delaware 19801, to, among other things: (i) determine whether to finally certify the Class for settlement purposes only pursuant to Court of Chancery Rules 23(a) and 23(b)(1); (ii) determine whether Plaintiffs and Plaintiffs’ Lead Counsel have adequately represented the Class, and whether they should be finally appointed as Class Representatives and Class Counsel, respectively, for the Class; (iii) determine whether the proposed Settlement should be approved as fair, reasonable, and adequate to Plaintiffs and the other Class Members; (iv) determine whether the proposed Judgment approving the Settlement, dismissing with prejudice the claims asserted against Defendants in the Action, and granting the Releases provided under the Stipulation should be entered; (v) determine whether the proposed Plan of Allocation of the Net Settlement Fund is fair and reasonable, and should therefore be approved; (vi) determine whether and in what amount any Fee and Expense Award should be paid out of the Settlement Fund, including any Incentive Awards to Plaintiffs to be paid solely from any Fee and Expense Award; (vii) hear and rule on any objections to the Settlement, the proposed Plan of Allocation, and/or Plaintiffs’ Counsel’s Fee and Expense Application, including Plaintiffs’ application for Incentive Awards to be paid solely from any Fee and Expense Award; and (viii) consider any other matters that may properly be brought before the Court in connection with the Settlement. Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 23 84. Any Class Member may object to the Settlement, the proposed Plan of Allocation, or Plaintiffs’ Counsel’s Fee and Expense Application, including Plaintiffs’ application for Incentive Awards (“Objector”); provided, however, that no Objector shall be heard or entitled to object unless, on or before November 13, 2026, such person: (1) files his, her, or its written objection, together with copies of all other papers and briefs supporting the objection, with the Register in Chancery at the address set forth below; (2) serves such papers (electronically by File & ServeXpress, by hand, by first-class U.S. mail, or by express service) on Plaintiffs’ Lead Counsel and Defendants’ Counsel at the addresses set forth below; and (3) emails a copy of the written objection to the following counsel: PLAINTIFFS’ LEAD COUNSEL Christine M. Mackintosh Erik W. Luedeke Grant & Eisenhofer P.A. Robbins Geller Rudman & Dowd LLP 123 Justison Street 655 W. Broadway 7th Floor Suite 1900 Wilmington, DE 19801 San Diego, CA 92101 cmackintosh@gelaw.com eluedeke@rgrdlaw.com Gregory E. Del Gaizo Robbins LLP 5060 Shoreham Place Suite 300 San Diego, CA 92122 gdelgaizo@robbinsllp.com DEFENDANTS’ COUNSEL Jay A. Dubow Troutman Pepper Locke LLP 3000 Two Logan Square Philadelphia, PA 19103 jay.dubow@troutman.com 85. Any objections must: (i) identify the case name and civil action number, “Schachter v. Robertson, C.A. No. 2023-1112-NAC”; (ii) state the name, address, and telephone number of the Objector and, if represented by counsel, the name, address, and telephone number of the Objector’s counsel; (iii) be signed by the Objector; (iv) state with specificity the grounds for and purpose of the objection, including a detailed statement of the specific legal and factual basis for each and Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 24 every objection and whether the objection applies only to the objector, to a specific subset of the Class, or to the entire Class; (v) if the Objector has indicated that he, she, or it intends to appear at the Settlement Hearing, state the identity of any witnesses the Objector may call to testify, and identify any exhibits the Objector intends to introduce into evidence at the hearing; and (vi) include documentation sufficient to prove that the Objector is a member of the Class. Plaintiffs’ Lead Counsel are authorized to request from any Objector additional information or documentation sufficient to prove that the Objector is a member of the Class. 86. You may file a written objection without having to appear at the Settlement Hearing. You may not, however, appear at the Settlement Hearing to present your objection unless you first file and serve a written objection in accordance with the procedures described above, unless the Court orders otherwise. 87. If you wish to be heard orally at the hearing in opposition to the approval of the Settlement, the Plan of Allocation, or Plaintiffs’ Counsel’s Fee and Expense Application, including Plaintiffs’ application for Incentive Awards (assuming you timely file and serve a written objection as described above), you must also file a notice of appearance with the Register in Chancery and serve it on Plaintiffs’ Lead Counsel and Defendants’ Counsel at the mailing and email addresses set forth in paragraph 84 above so that the notice is received on or before November 13, 2026. Persons who intend to object and desire to present evidence at the Settlement Hearing must include in their written objection or notice of appearance the identity of any witnesses they may call to testify and exhibits they intend to introduce into evidence at the hearing. Such persons may be heard orally at the discretion of the Court. 88. You are not required to hire an attorney to represent you in making written objections or in appearing at the Settlement Hearing. However, if you decide to hire an attorney, it will be at your own expense, and that attorney must file a notice of appearance with the Court and serve it on Plaintiffs’ Lead Counsel and Defendants’ Counsel at the mailing and email addresses set forth in paragraph 84 above so that the notice is received on or before November 13, 2026. 89. The Settlement Hearing may be adjourned by the Court without further written notice to Class Members. If you intend to attend the Settlement Hearing, you should confirm the date, time, and location with Plaintiffs’ Lead Counsel. 90. Unless the Court orders otherwise, any Class Member who does not object in the manner described above will be deemed to have waived any objection (including the right to appeal) and shall be forever foreclosed from Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 25 making any objection to the proposed Settlement, the proposed Plan of Allocation, Plaintiffs’ Counsel’s Fee and Expense Application, including Plaintiffs’ application for Incentive Awards, or any other matter related to the Settlement or the Action, and will otherwise be bound by the Judgment to be entered and the Releases to be given. Class Members do not need to appear at the Settlement Hearing or take any other action to indicate their approval. CAN I SEE THE COURT FILE? WHOM SHOULD I CONTACT IF I HAVE QUESTIONS? 91. This Notice contains only a summary of the terms of the proposed Settlement. For more detailed information about the matters involved in the Action, you are referred to the papers on file in the Action, including the Stipulation, which may be inspected during regular office hours at the Office of the Register in Chancery in the Court of Chancery of the State of Delaware, New Castle County, Leonard L. Williams Justice Center, 500 North King Street, Wilmington, DE 19801. Additionally, copies of the Stipulation and any related orders entered by the Court will be posted on the Settlement website, www.LionElectricStockholdersLitigation.com. If you have questions regarding the Settlement, you may contact the Settlement Administrator by mail at Lion Electric Stockholders Litigation, c/o JND Legal Administration, P.O. Box 91250, Seattle, WA, 98111; by telephone at 1-855-961-0957; or by email at info@LionElectricStockholdersLitigation.com. You may also contact Plaintiffs’ Lead Counsel: Christine M. Mackintosh, Grant & Eisenhofer P.A., 123 Justison Street, 7th Floor, Wilmington, DE 19801, (302) 622-7000 (telephone), cmackintosh@gelaw.com (email); Erik W. Luedeke, Robbins Geller Rudman & Dowd LLP, 655 W. Broadway, Suite 1900, San Diego, CA 92101, (619) 231-1058 (telephone), eluedeke@rgrdlaw.com (email); and Gregory E. Del Gaizo, Robbins LLP, 5060 Shoreham Place, Suite 300, San Diego, CA 92122, (619) 525-3990 (telephone), gdelgaizo@robbinsllp.com. Do not contact the Court or its staff with questions about the terms of the proposed Settlement. WHAT IF I HELD SHARES ON SOMEONE ELSE’S BEHALF? 92. If you are a broker or other nominee that held NGA Class A common stock through the Redemption Deadline, as a record holder for the beneficial interest of persons or entities other than yourself, you are requested to either: (i) within seven (7) calendar days of receipt of this Notice, request from the Settlement Administrator sufficient copies of the Notice and Proof of Claim and Release (the “Notice Packet”) Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 26 to forward to all such beneficial owners and, within seven (7) calendar days of receipt of those Notice Packets, forward them to all such beneficial owners; or (ii) within seven (7) calendar days of receipt of this Notice, provide a list of the names, addresses, and, if available, email addresses of all such beneficial owners to Lion Electric Stockholders Litigation, c/o JND Legal Administration, P.O. Box 91250, Seattle, WA 98111; by telephone at 1-855-961-0957; or by email at LELSecurities@ LionElectricStockholdersLitigation.com. If you choose the second option, the Settlement Administrator will send a copy of the Notice Packet to the beneficial owners. Brokers, nominees, and their agents are requested to forward the Notice Packet to (or identify names, mailing addresses, and email addresses of) all beneficial owners who held NGA Class A common stock through the Redemption Deadline, regardless of whether or not those beneficial owners have enrolled in a claim-filing program with their broker or financial institution. Upon full compliance with these directions, such nominees may seek reimbursement of their reasonable expenses actually incurred by providing the Settlement Administrator with proper documentation supporting the expenses for which reimbursement is sought. A copy of the Notice Packet may also be obtained from the Settlement website, www.LionElectricStockholdersLitigation.com, by calling the Settlement Administrator toll-free at 1-855-961-0957, or by emailing the Settlement Administrator at LELSecurities@ LionElectricStockholdersLitigation.com. DO NOT CALL OR WRITE THE COURT OR THE OFFICE OF THE REGISTER IN CHANCERY ABOUT THIS NOTICE OR QUESTIONS ABOUT THE TERMS OF THE PROPOSED SETTLEMENT Dated: October 2, 2026 BY ORDER OF THE COURT OF CHANCERY OF THE STATE OF DELAWARE Questions? Visit www.LionElectricStockholdersLitigation.com or call toll-free at 1-855-961-0957 27