SFDR

Responsible Investment Policy for Njord Alternative Investments

The Sustainable Finance Disclosure Regulation 2019/2088 ("SFDR") on sustainability-related disclosures in the financial sector requires alternative investment fund managers to provide information on the funds under management, as well as integrating sustainability risks and negative sustainability impacts into the funds' investment decisions.

Njord Alternative Investments (NAI) understands a sustainability risk as “an environmental, social or governance event or condition that, if it occurs, could cause a negative material impact on the value of an investment”. Sustainability risks may result from the investments made by NAI on behalf of its investment mandates but may also be exogenous risks that could pose challenges to the investments and their projected returns in the future. NAI believes that adverse sustainability impacts are important to avoid as they can reduce the risk adjusted returns in its investment portfolios.

SFDR establishes disclosure and reporting requirements under three sets of rules, depending on the fund's investment strategy and how the fund is marketed. All funds must follow one of the three sets of rules based on the integration and weighting of sustainability: dark green funds (SFDR Article 9), light green funds (SFDR Article 8), and mainstream funds (SFDR Article 6).

Article 9 - funds with a sustainable investment objective

Article 8 - funds that promote environmental and/or social characteristics.

Article 6 - funds that consider sustainability from a risk management perspective.

The Funds are classified as mainstream funds under SFDR Article 6. This means that the funds are funds that do not have a sustainable investment objective in accordance with SFDR Article 9, and do not, through their investments, promote environmental or social characteristics, or a combination of these in accordance with SFDR Article 8. The Funds are not required to make sustainable investments in accordance with SFDR Article 2(17).

This information is provided solely to comply with the requirements of the SFDR and shall not be binding or create any obligations for the Company. The only basis for legal obligations between the Company and investors in the Funds under management are the pre-contractual information provided in the fund documentation, including subscription forms.

Integration of Sustainable risk

"Sustainability risk" means an environmental, social or governance event or circumstance that could have an actual or potential significant negative impact on the value of the investment if it were to occur. Sustainability risks can materialise throughout the investment lifecycle. As part of the Funds' investment strategy and risk monitoring, the Company considers sustainability risks in its investment processes as described in the fund documentation or, if relevant, the supplement to the fund documentation, relating to each fund.

According to SFDR Article 3, information must be published regarding the integration of sustainability risks in the investment decisions made by the Company on behalf of Funds.

• Social risk, such as negative events related to health and safety associated with the technical building conditions and construction of real estate and pollution.
• Physical climate risk, such as extreme weather or other climate risks that exposes the real estates and/or other real estate investments to physical damage.
• Transition risk related to, for example, future climate and environmental legislations on energy consumption and greenhouse gas emissions, technological changes, and changes in market preferences.

Sustainability risk may have a significant impact on the value and/or return of the fund’s investments. A materialised sustainability risk may, among other things, necessitate new investments in the form of improvement measures on the affected real estate, or investments in climate measures because of new or amended regulatory requirements for real estate. Sustainability risks may also create challenges with regards to raising capital in the future.

The consequences of sustainability risks will vary depending on the specific risk that materialises. By taking sustainability risks into consideration, the aim is to identify these risks and respond appropriately to minimize the impact on the Funds' investments.

Negative consequences of Sustainability factors

According to SFDR Article 4, information on the consequences of investment decisions that lead to negative impacts on sustainability factors must be published. Sustainability factors include environmental, social conditions, the relationship with employees, respect for human rights, and anti-corruption.

Taxonomy Regulation Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment and amending Regulation (EU) 2019/2088 ("Taxonomy Regulation") is a classification system aimed at establishing common criteria for environmentally sustainable economic activities. The Taxonomy Regulation also provides additional requirements for information that financial market participants must disclose in accordance with the SFDR. As the Funds are neither categorized as "light green" products under SFDR Article 8 nor "dark green" products under SFDR Article 9, the following statement is included in accordance with Article 7 of the Taxonomy Regulation: The underlying investments of the Funds does not take into consideration the EU criteria for environmentally sustainable economic activities as defined in the Taxonomy Regulation.

Compensation Scheme

In accordance with Article 5 of SFDR, the Company shall include information in their remuneration policies information on how those policies are consistent with the integration of sustainability risks.

The company have focus long-term when it comes to sustainability, so we are not offering remuneration to ensure that there are no incentives to take unnecessary risks related to sustainability.