Policy on integration of sustainability risks in investment decision-making process
1. Background and purpose
1.1 As an alternative investment fund manager regulated by the Danish Financial Supervisory Authority, and consequently as a financial market participant for purposes 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 from time to time, including any delegated regulations or legislation promulgated thereunder ("SFDR"), Bifrost ManCo ApS ("Bifrost ManCo") is subject to the SFDR.
1.2 In accordance with Article 3(1) of the SFDR, this policy describes how sustainability risks are integrated in the investment decision-making process of Bifrost ManCo when making investments on behalf of the alternative investment funds managed by Bifrost ManCo (each a "Fund").
1.3 A 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.
2. No integration of sustainability risks in investment decision-making process
2.1 Bifrost ManCo only manages Funds that are classified as an Article 6 product in accordance with the SFDR. Accordingly, each Fund will not have sustainable investment as its objective, nor will it promote environmental or social characteristics.
2.2 The adverse impacts on sustainability factors of investment decisions for a Fund will not be considered by Bifrost ManCo nor will any investment made by a Fund take into account the EU criteria for environmentally sustainable economic activities under Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment.
2.3 Irrespective of the circumstances described in sections 2.1 and 2.2, Bifrost ManCo acknowledges that there may be environmental (including physical and transitional risks), social and/or governance risks which could impact a Fund (including its financial returns) and/or Bifrost ManCo. Notwithstanding Bifrost ManCo's awareness that such sustainability risks may exist (or come into existence) for a Fund and its underlying investment(s), Bifrost ManCo does not, however, consider such risks to be of relevance to its investment decisions, as Bifrost ManCo focuses on compliance with the Fund's purpose, investment strategy and investment guidelines (under which sustainability matters (including sustainability risks) is not an element) in its investment decision-making process for the Fund.
2.4 Accordingly, Bifrost ManCo has decided not to integrate sustainability risks into its investment decision-making process for a Fund. Bifrost ManCo also does not take measures to mitigate sustainability risks in its investment decision-making process for a Fund.
2.5 For the same reason as described above, Bifrost ManCo does not assess the likely impacts of sustainability risks on the financial returns of a Fund.
3. Annual review for the policy
3.1 This policy shall be reviewed at least once a year by the board of directors of Bifrost ManCo.
3.2 Any changes to the policy must be adopted by the board of directors, and the general partners of Bifrost ManCo will be responsible for incorporating the changes.