SFDR and sustainability disclosures

SFDR statement — Highvern AIFM Services AS

9 November 2026 (v.3)

This statement is made in accordance with the SFDR and has been prepared for the purpose of meeting the disclosure requirements in article 3, 4, 5 and 10 of the SFDR.

SFDR requires financial market participants and financial advisers to publish information on their website about their policies on the integration of sustainability risks in their investment decision-making and investment advice, including whether and how adverse impacts of investment advice are considered and how remuneration policies are consistent with the integration of sustainability risks in investment decision-making and investment advice.

The SFDR is applicable to Highvern AIFM Services AS (“Highvern AIFM”) according to the Norwegian act of 22 December 2021 no. 161 on disclosure of sustainability information in the financial sector and a framework for sustainable investments.

Sustainability risk – Article 3

According to article 2(22) of the SFDR, sustainability risk means 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.

Highvern AIFM will consider sustainability risks in its decision-making process by ensuring that potential portfolio investments are screened with regards to sustainability risks. For some funds, the portfolio management is outsourced from Highvern AIFM to a third party with separate license. Each such party have their own policy on how to address risks, including sustainability risks.

When portfolio management is outsourced, Highvern AIFM’s role is to ensure that all applicable risks are considered in the decision–making process according to the portfolio manager’s policies.

No consideration of adverse impacts of investment decisions on sustainability factors – Article 4

Article 4 of the SFDR requires financial market participants to publish information regarding whether they consider principle adverse impacts (“PAIs”) of investment decisions on sustainability factors. Based on an assessment of Highvern AIFM’s allocation of resources and as a fund hotel, Highvern AIFM has resolved not to undertake an evaluation of the potential adverse effects that each individual underlying investment may have on various sustainability indicators.

Remuneration policy – Article 5

Pursuant to Article 5 of the SFDR, financial market participants are required to disclose information on how their remuneration policy is consistent with the integration of sustainability risks into their decision-making processes.

Highvern AIFM has adopted a written remuneration policy designed to promote sound management and control of the risks relating to the funds under management and not to encourage excessive risk taking. To enable Highvern AIFM to implement its investment strategies effectively, it is important that Identified Staff, including persons who make investment decisions, do not have incentives that conflict with the objective of taking sustainability risks into account when making investment decisions.

Highvern AIFM’s remuneration policy therefore states that employees shall take sustainability risks into account and to comply with Highvern AIFM’s applicable policies and procedures. Compliance with such requirements forms part of the qualitative assessment of variable remuneration.

Product level disclosures – Article 10

With reference to product (i.e. fund) level disclosures, we refer to the investor’s customary investor relations contact of the applicable fund.

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