SFDR DISCLOSURES FOR SFCompliance AS & Kvilesteinen Investering AS

The purpose of this document is to disclose how SFCompliance AS (“SFC”) at current act in relation to the obligations of SFDR.

SFDR Article 3

Sustainability policies in the investment process.

The investment process will be carried out in order to fulfil the obligations of the investment mandate of the funds under management. If sustainability risks should be implemented in the investment mandate of the fund SFC will take the necessary steps to ensure compliance to this in the investment process.

For those situations that sustainability risks is not a part of the investment mandate such risks will not be a part of the investment decision process.

SFDR Article 4

Principal adverse impacts

Currently SFC does not consider principal adverse impacts, as described in article 4 of the SFDR, on sustainability factors as a consequence of investment decisions made.

We have come to this conclusion as we expect significant challenges in obtaining information of sufficient quality on a needed level of detail from our current and potential investment objects. The lack of quality and detail will prevent us from reporting meaningful figures on the principal adverse impact indicators set out in the regulatory technical standards accompanying the SFDR.

However, SFC will consider reporting on principal adverse impacts if and/or when relevant information of relevant quality is available.

SFDR Article 5

Remuneration policy

Our remuneration policy aims to reduce the incentives to take excessive risk in the asset management process. Sustainability risks are not a part of the overall risks as implemented in the asset management agreement between SFC and the fund Kvilesteinen Investering AS.

SFDR Article 6

Transparency of the integration of sustainability risks at product level – Kvilesteinen Investering AS As the investment mandate of Kvilesteinen Investering AS do not include sustainability risks as parameter neither in the risk section nor in the limits section SFC has concluded that sustainability risks shall be exempted from the investment decision process.
At current SFC estimate that integration of sustainability risks in the investment process can reduce the investment universe and as such substantially increase the range of estimated return for the fund.