No consideration of adverse impacts of investment decisions on sustainability factors
Bifrost ManCo ApS ("Bifrost ManCo") does not consider any adverse impacts of its investment decisions on sustainability factors at entity level, as referred to in Article 4(1), point (b), of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector, as amended.
This position reflects Bifrost ManCo's current assessment of the relevance, data availability, and methodological robustness of sustainability indicators in relation to the investment strategy of alternative investment funds managed by Bifrost Manco. In particular, limitations in the consistency, quality, and comparability of sustainability data across asset classes and investee entities, as well as the nature of the managed funds' investment approach, mean that a comprehensive and reliable assessment of principal adverse impacts is not currently feasible.
Bifrost ManCo will keep this position under periodic review and may revise its approach in the future should regulatory guidance, market practices, or data availability evolve in a manner that enables a robust and proportionate consideration of adverse impacts of investment decisions on sustainability factors.
The statement is given as of March 9th 2026 and will be reviewed and, where relevant, updated no later than 30 June each calendar year.