1. Definition

It is our policy that Nordic Bloom P/S, in its decision-making process regarding any investment, includes an assessment of the sustainability of the investment and excludes investments that involve particular sustainability risks.

1.1

According to EU Regulation 2019/2088 of 27 November 2019, sustainable investment means: "An investment in an economic activity that contributes to an environmental objective as measured, for example, by key performance indicators for resource efficiency for the use of energy, renewable energy, raw materials, water, land, for waste generation, for greenhouse gas emissions or for its impact on biodiversity. An investment in an economic activity that contributes to an environmental objective, as measured, for example, by key performance indicators on resource efficiency for the use of energy, renewable energy, raw materials, water and land, for waste generation and greenhouse gas emissions or for its impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to fighting inequality or that promotes social cohesion, social inclusion and labour relations, or an investment in human capital or economically or socially disadvantaged communities, provided that such investments are not significantly detrimental to any of those objectives and that the enterprises invested in follow good governance practices, in particular as regards sound management structures, labour relations, staff remuneration and tax compliance."

2. Venture funds

2.1

Through our venture funds, we invest in future technology, pharmaceuticals, medical devices and other future solutions to a challenge in today's world. The investment policy will be much broader than investing in projects that promote sustainability, but the funds' portfolios will usually also include such investments. And as far as possible, we ensure that no investments are made in companies whose projects or behaviour involve particular sustainability risks.

2.2

Our primaries funds invest through 15-20 top tier US venture funds - primarily Silicon Valley based - carefully selected based on the historical performance of their management teams. In doing so, we ensure that the fund has adopted the Principles of Responsible Investment (PRI) or otherwise as part of its investment policy rejects investments in companies whose purpose or behaviour contradicts sustainability principles.

2.3

Our secondaries funds invest partly through venture funds and partly through direct investments in companies. When selecting venture funds, as in the primaries funds, we ensure that the fund in question has signed up to PRI or otherwise as part of its investment policy rejects investments in companies whose purpose or behaviour contradicts sustainability principles. And in direct investments, we ourselves exclude such companies.

3. Assessing sustainability

3.1

When assessing whether a company's purpose or behaviour contradicts sustainability principles, we consider the following in particular:

• Whether the company's product or service either during its production or when delivered by unnecessary use of black energy, by harmful, including polluting or hazardous substances, by noise, vibrations, smoke or similar negatively affects climate, environment, nature, wildlife, people, the surrounding community.
• Whether the company ensures compliance with the principles of non-discrimination and the company's management ensures a working environment, both physical and psychological, that does not expose the company's employees to danger, harm or unnecessary strain.
• That the company complies with applicable rules, including paying taxes, duties and other mandatory payments to public authorities, acting in accordance with good business practice and otherwise acting responsibly towards the surrounding community.

4. Impact on returns

4.1

It is our expectation that the reduction of sustainability risks implied by our investment policy and decision-making process mentioned above will lead to a reduction of the overall risk in our funds and thus - all else being equal - an improved risk-return.

5. Remuneration policy

5.1

The integration of sustainability assessment and opting out of sustainability risks in our investment policy and decisions, as described above, is not part of our remuneration policy, but is part of the responsibility of the relevant employees.