Sustainability Policy

Investment philosophy
Norron’s aim is to create competitive returns through responsible investments. In order to optimize the returns for our shareholders, our strategy and investment philosophy is based on four cornerstones:

RESPONSIBILITY

COMPETENCE

ACCESSIBILITY

TRANSPARENCY

In our investment management, we will promote sustainability and consider and integrate sustainability risks in the investment process. Norron’s investments should contribute to fulfilling Agenda 2030 and the Sustainable Development Goals (SDGs), as well as the Paris Agreement’s goal of limiting global warming to 1.5°C.

Purpose

The purpose of this policy is to establish a framework for responsible investments in Norron’s portfolio management and to foster long-term sustainable development for the business, investors, collaborators, and other stakeholders.

Targets
Norron has set three entity-level sustainability goals, which all sub-funds shall contribute to:

Target		SDG contribution	KPI
E	All portfolio companies shall set SBTi-validated targets	13, 17	50% by 2026 (100% by 2040)
S	All portfolio companies shall sign the UN Global Compact	8, 10, 11, 16	90% by 2026 (100% by 2040)
G	All portfolio companies shall disclose sustainability-related risks	8, 16	90% by 2026 (100% by 2040)

Governance

Norron shall operate in accordance with the UN Principles for Responsible Investments (UN PRI) and the UN Global Compact’s principles. Through these principles, we commit to consider sustainability in investment analysis and decision-making.

Norron shall apply exclusion criteria, meaning that we will exclude certain industries and companies that do not meet our basic requirements.

Norron’s shall integrate significant sustainability risks and factors into investment decisions. Norron’s funds will promote sustainability and, at a minimum, classify as Article 8 under the EU SFDR.

Norron shall be an active owner, using our influence as investors to encourage companies to make sustainable and profitable decisions. We engage in ongoing dialogue with companies, regularly monitor them, and vote at shareholders’ meetings when deemed appropriate.

Norron shall continuously monitor all companies in which we are invested, and follow our escalation approach in the event of a sustainability incident.

Monitoring and reporting
Norron shall annually monitor the companies in which we are invested based on a set of sustainability indicators. This involves tracking data in accordance with the EU taxonomy for sustainable investments and the EU SFDR. We also assess companies based on Norron’s entity-level sustainability goals and their contributions to the UN Sustainable Development Goals.

For Norron’s Article 9 funds, reporting will also align with the fund’s established sustainability goals and objectives.

Norron shall provide information about its responsible investment practices and sustainability efforts on its website and in an annual sustainability report. Norron shall also keep stakeholders and affiliated organizations informed about its sustainability initiatives through ongoing dialogues and newsletters.

Responsibility
The Board of Directors is ultimately responsible for Norron’s sustainability efforts and ensures that this policy is updated and approved annually. The CEO is responsible for implementing and maintaining the policy within the organization.

Norron’s sustainability manager will be responsible for the daily sustainability efforts, working together with the fund managers of each respective fund. Norron’s ESG team will oversee, coordinate, and monitor Norron’s shareholder engagement and sustainability efforts. The team is responsible for the ESG Watchlist.

This policy covers all Norron employees.

Last approved by the Board of Directors of Norron AB on December 6 2023.