Environmental, Social and Governance policy

1. Introduction

Norvestor Equity AS ("Norvestor") recognises the impact private equity owned companies may have on the environment and society at large, and is therefore strongly committed towards promoting sound principles for the protection of the environment, social responsibility and proper governance practices (ESG principles) in the course of its business conduct.

This environmental, social and governance policy (ESG policy) is developed for the purpose of promoting and maintaining a proper decision-making processes that focuses on high environmental, social and governance standards. See also section 6 below for more details on the matter of responsible investments.

Norvestor in its capacity as investment adviser/manager to private equity funds is committed to be in compliance with applicable rules and regulations, which includes adherence to fundamental ESG principles as demonstrated by internationally recognised conventions and principles (such as the United Nations Universal Declaration of Human Rights, the UN Global Compact’s ten principles, OECD Guidelines for Multinational Enterprises etc.).

2. Environmental

Norvestor seek to minimise environmental impact, and encourage environmental consciousness. Norvestor do not accept products or working routines that are unreasonably harmful to the environment or components of products that do not live up to high ethical, environmental and safety-related standards.

Environmental impact and risks are considered prior to any investment decision by the funds, and Norvestor seek to minimise the environmental impacts of the funds’ businesses through means such as careful use of resources, optimisation of operations, recycling and handling of waste.

3. Social

The investment strategies of the funds reflect that all business activities must uphold respect for internationally recognised human rights principles.

Discrimination based on gender, age, race, sexual orientation or religion etc. is not tolerated, nor does Norvestor accept neglect of health and safety issues. Norvestor respects applicable national and international labour laws, and works to ensure proper labour and working conditions.

It is Norvestor’s objective to be socially responsible with regard to investments, and to contribute to the development of the communities in which portfolio companies operate by promoting sustainable and profitable growth of the portfolio companies.

4. Governance

Norvestor acknowledges the importance of good corporate governance in connection with its business, and thus adheres to all applicable anti-corruption laws and best practice standards. The principles of fair business, marketing and advertising practices is upheld by Norvestor, and we will seek to take all reasonable steps to ensure the quality and reliability of the goods and services provided by Norvestor and the portfolio companies.

Norvestor will exhibit honesty, integrity, fairness and respect in all its business dealings, and not make representations or omissions, nor engage in any other practices that are deceptive, misleading, fraudulent or unfair.

5. Application

Norvestor will conduct its activities and affairs in compliance with the ESG policy. ESG issues will be incorporated into investment analysis and decision-making processes. If it becomes clear that Norvestor, the funds or any portfolio company, is in material breach of the adopted ESG policy, reasonably necessary actions will be made to rectify any such breach.

6. Responsible investment

6.1 Principles for Responsible Investment

Through this ESG policy Norvestor seeks to comply with the United Nations-supported Principles for Responsible Investment (“PRI”) (please see: http://www.unpri.org/about-pri/the-six-principles/). In accordance with PRI, Norvestor is committed to the incorporation of ESG issues into investment analysis, decision-making processes, and portfolio companies’ policies and practices. As part of this commitment Norvestor considers and identifies performance on ESG issues not only to mitigate risks but also to find opportunities that can add value by way of enhancing the management’s focus on ESG issues.

6.2 Portfolio companies

Norvestor will work closely with portfolio companies to build businesses with a likeminded commitment towards ESG issues. As a consequence of this, Norvestor provides portfolio companies with appropriate tools and guidance, and encourage and support the portfolio companies in their adaptation of a structured approach to managing ESG risks and opportunities.

Norvestor requires portfolio companies to review their ESG work, and report to Norvestor on their adherence and progress. Norvestor makes use of the information to quantitatively measure ESG issues and their impacts on the performance of each portfolio company.