Arctic Alternative Investments Management AS ("AAIM") will use reasonable endeavours to consider relevant risks related to sustainability (environmental, social and governance aspects) when making investment decisions. AAIM shall ensure that prior to any investment decision being made, consideration has been given as to whether, and the extent of, sustainability risks have been considered in the due diligence process.
POLICY FOR INTEGRATION OF SUSTAINABILITY RISK
Arctic Alternative Investments Management AS ("AAIM") has implemented a policy for integration of sustainability risks in its investment decision-making process.
AAIM will use reasonable endeavours to consider relevant risks related to sustainability (environmental, social and governance aspects) when making investment decisions.
‘Sustainability risk’ shall herein mean an "environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment" in accordance with Regulation (EU) 2019/2088 ("SFDR").
AAIM shall ensure that prior to any investment decision being made, consideration has been given as to whether, and the extent of, sustainability risks have been considered in the due diligence process.
If AAIM considers sustainability risks to be relevant, but no such consideration has been made, AAIM shall notify either the relevant placement agent or external counsel and ask for an explanation.
Further, AAIM shall, during the investment decision process, consider the likely impacts sustainability risks may have on the return of the fund in question.
The compliance officer at AAIM shall ensure that AAIM's considerations are documented.
SUSTAINABLE FINANCE DISCLOSURE REGULATION
Article 5 of the SFDR requires an AIFM to include information in their remuneration policies on how such policies are consistent with the integration of sustainability risks.
The remuneration policy of AAIM aims to promote sound and effective governance and risk management.
AAIM does not offer variable remuneration. Only providing fixed remuneration ensures that the remuneration policy does not encourage excessive risk taking with respect to sustainability risks, but instead that investment decisions is taken with a long-time perspective whereby sustainability risks is taken into consideration.
PRINCIPAL ADVERSE SUSTAINABILITY IMPACTS STATEMENT
AAIM is required to make certain disclosures pursuant to the SFDR. One such disclosure is related to transparency of adverse sustainability impacts at entity level, which broadly speaking is a comply or explain regime with regards to whether AAIM considers principal adverse impacts of investment decisions on sustainability factors. This is what is covered in this section. Another related topic is transparency relating to sustainability risk policies, and information about the policies AAIM has in relation to integration of sustainability risks in its investment-making process. This is covered in the section “policy for integration for sustainability risk”.
AAIM has decided to not consider adverse impacts of investment decisions on sustainability factors pursuant to article 4 of the SFDR. The reason for this is the legal uncertainty of the requirements until the regulatory technical standards are in place. AAIM will monitor the situation and consider this at a consecutive basis.