In relation to the regulation regarding sustainability disclosure in the financial sector Sustainable Finance Disclosure Regulation, (SFDR)1, Nordian makes the following announcements.

Integration of sustainability risks

A sustainability risk is "an environmental, social or governance event or circumstance that, if it occurs, could have an actual or potential material adverse effect on the value of the investment".

Before investment decisions are made on behalf of any Nordian fund managed by us, an internal investment procedure is followed, including approval from our Investment Committee. We consider ESG a standard topic in the investment procedure. Part of this procedure is that we seek to assess the risks of a potential investment, including sustainability risks. Identified sustainability risks are considered by us, when making an investment decision.

We continually strive to integrate sustainability considerations into our own business processes and those of our portfolio companies. Our approach focuses on 3 principles:

  1. Sustainability issues are an integrated part of our investment policy;

  2. Together with the management of our portfolio companies, we define an ESG policy with associated priorities and objectives;

  3. In addition to regular monitoring and reporting on ESG, we strive to address and highlight potential ESG risks and opportunities.

Sustainability aspects are part of our criteria when selecting a potential investment. We are then actively involved in the portfolio company with the objective of working with management to improve ESG performance.

Nordian employees receive a combination of fixed remuneration and variable remuneration. The remuneration of the employee concerned takes into account, among other things, compliance with all of the Manager's internal policies and procedures.

Transparency of negative sustainability impacts

In accordance with Article 4(1)(b) of the SFDR, Nordian declares that it does not take into account the negative impact of investment decisions on sustainability factors as referred to in Article 4(1)(a) of the SFDR and, therefore, does not make the communication referred to in Article 4(1)(a) of the SFDR. Given the small size of Nordian's organization, such a notice, and the administrative burden involved, would not be proportionate. This does not mean that Nordian does not consider the negative impact of its investment decisions on sustainability factors in accordance with Article 4(1b) of Regulation (EU) 2019/2088 (SFDR).