SFDR disclosure

As investors, we have a unique opportunity to drive innovation and contribute to sustainable growth that has a positive impact on people and the planet. We seek to accomplish positive net impact through a responsible investment policy and continuous focus and effort on the matter together with the companies in ourportfolio.

European Union Sustainable Financial Disclosure Regulation 2019/2088 (SFDR).
SFDR shall provide better insight concerning sustainability of financialproducts, make ESG information more comparable and reduce the scope ofso-called greenwashing, i.e., prevent erroneous claims about the sustainability of a financial product.

In the framework, funds are classified as Article 9 funds (dark green), Article 8funds (light green) and Article 6 funds (all other funds). Article 9, also referred to as “products targeting sustainable investments”, covers products targeting bespoke sustainable investments and those that have sustainable investment as their objective. Article 8 promote environmental or social characteristics, or a combination of those characteristics, provided the companies in which investments are made, follow good governance practices. As of now, we consider Article 8 relevant to all active funds under management.

Our approach towards sustainability, ESG and impact
Considering sustainability, we use the definition set by the UN: “meeting the needs of the present without compromising the ability of future generations to meet their own needs.” Further, impact investing to us means seeking to make a measurable net positive environmental or social effect through the portfolio companies, while ESG (environmental, social and governance) analysis is an approach towards identifying non-financial risks or opportunities that may have a material impact on an asset's value.

In Skagerak Capital we have a holistic approach towards sustainability, ESG and impact, whereas all dimensions are included in our investment process, monitoring and in developing the portfolio companies.

Through our investment scope we aim to include companies in our portfolio with a net positive impact on people and the planet. To comply with the scope, we consider all three elements, whereas we conduct impact related workshops, as well as UN SDG mapping. In addition, we have integrated means to disclose ESG-related threats and opportunities in our active investment strategies. We work through a third party to identify companies that may pose a risk to ESG related elements. If we consider the risks to be too great, we refrain from investing in thesecompanies.

Throughout the lifetime of the funds, we closely monitor the performance of the portfolio companies and we have dedicated employees to secure the company’s alignment to our investment strategy. We have developed our own ESG-scorecard system to track, benchmark and improve the performance of the portfolio companies. Additionally, we work closely with the management, seeking to enhance their performancewithin ESG.

Remuneration policies
ESG-factors is integrated part of ensuring long term sustainable value creation and is a natural part of both investment processes and in developing the portfolio companies in Skagerak Capital. Even though there are no KPIs directly linked to our remuneration policies, ESG-factors is one of many facets in the assessment of performance and renumeration reviews.

No consideration of Principal Adverse Impact (PAI)
Given that Regulatory Technical standards are yet to be finalized and adopted by European legislators, Skagerak Capital does not currently consider the principal adverse impact of investment decisions on sustainability factors asset out under the European Union Sustainable Financial Disclosure Regulation 2019/2088 (SFDR).

Final remarks
We take great pride in the companies in our portfolio, and we are excited overthe possibilities that lies ahead of us. With this in mind, we also acknowledge that working towards greater impact and alignment of strategy and standards requires effort. We will always strive to improve the work we do together with the companies, and how Skagerak Capital, as an investor, can contribute to have apositive impact on people and the planet.