To our stakeholders: I am pleased to confirm that Norron Asset Management reaffirms its support of the United Nations Global Compact’s Ten Principles in the areas of Human Rights, Labour, Environment and Anti-Corruption. In our annual Communication on Progress, we describe our dedication and approach to implement and continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. For two of our six funds, we apply an investment philosophy that aims to contribute to sustainable development and the SDG:s. Moreover, we have set a target during the year for 90% of our investees to sign the UN Global Compact until 2026. We also commit to sharing this information with our stakeholders via our regular channels of communication.

Yours Sincerely,

Alexander Zetterquist, CEO

• Our funds are either classified as Article 8 or Article 9 funds according to SFDR, implying that we promote sustainability in our investments and that sustainability is an integral part of our investment process
• Promoting the membership of the UN Global Compact and the 10 principles internally, with our stakeholders and our investees. Our target is to reach 90% signatories in our portfolio until 2026.
• For our sustainable investments we require our holdings to comply with the Minimum Safeguards criteria (OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights and ILO core conventions)
• The 10 principles are incorporated in our Policy on Responsible Investments

• Our ESG Council monitors and observes our investees and potential breaches against international norms.
• Our Policy on Responsible Investments outlines our commitment to work in alignment with the UN Global Compact and to take human rights into account in our investment decisions.
• ESG factors are integrated in our investment philosophy and we apply the UN Principles for Responsible Investments in our decision making

• Companies involved in any breaches related to Human Rights will be assessed and based on the severity, set on our ESG Watchlist and excluded from our portfolios if not actions are taken.
• Through our annual ESG Questionnaire, we gather and assess information on our investees’ work with human rights and alignment with the UN Guiding Principles on Business and Human Rights as well OECD Guidelines for Multinational Enterprises
• We complete regular ESG analyses of all our investees where the Human Rights aspect is pivotal
• Executes consultation and engagement activities with our investees relating to ESG
• We measure our alignment with UN Global Compact and we follow up all our investees against Minimum Safeguards and monitors potential incidents

• Our funds are either classified as Article 8 or Article 9 funds according to SFDR, implying that we promote sustainability in our investments and that sustainability is an integral part of our investment process
• Promoting the membership of the UN Global Compact and the 10 principles internally, with our stakeholders and our investees. Our target is to reach 90% signatories in our portfolio until 2026.
• For our sustainable investments we require our holdings to comply with the Minimum Safeguards criteria (OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights and ILO core conventions)
• The 10 principles are incorporated in our Policy on Responsible Investments
• Norron AB respects the right of all employees to join a trade union of their choice without fear of intimidation or reprisal, in accordance with national law
• Norron AB complies with minimum wage standards and does not participate in any form of forced labour or child labour
• We consider hours of work/rest and have paid holidays
• We ensure that employment-related decisions are based on relevant and objective criteria

• Our ESG Council monitors and observes our investees and potential breaches against international norms
• Our Policy on Responsible Investments outlines our commitment to work in alignment with the UN Global Compact and to take Labour Rights into account in our investment decisions
• ESG factors are integrated in our investment philosophy and we apply the UN Principles for Responsible Investments in our decision making
• Our policy on responsible investments highlights our objective for all our investees to sign the UN Global Compact and as such promote decent work and economic growth and the other principles included

• Companies involved in any breaches related to Labour Rights will be assessed and based on the severity, set on our ESG Watchlist and excluded from our portfolios if not actions are taken.
• In our annual ESG Questionnaire we gather information on our investees’ actions and policies relating to labor rights, governance and employee relationships
• We value diversity in the board, executive management and in the workforce of our investees and gather this information through our annual questionnaire and regular analyses
• We complete regular ESG analyses of all our investees where the Labour Rights aspect is pivotal
• Executes consultation and engagement activities with our investees relating to ESG
• We measure our alignment with UN Global Compact and we follow up all our investees against Minimum Safeguards and monitors potential incidents

• Our funds are either classified as Article 8 or Article 9 funds according to SFDR, implying that we promote sustainability in our investments and that sustainability is an integral part of our investment process
• We want to invest in companies that contribute to the combat of climate change and with a clear positive sustainability impact
• We strive to invest in companies that through their products and/or service offerings can contribute to a positive environmental impact, for example by enabling activities, circular processes and innovations
• Our Policy on Responsible Investments outlines that our investments should contribute to Agenda 2030 and the Paris Agreement’s goals of limiting the global warming to 1.5 °
• We have committed to the Science Based Targets initiative and will submit targets covering our own operations and our investees
• Annual tracking and reporting on the climate footprint of our funds

• Robust recycling systems at our premises
• Educational sessions and workshops in sustainability and how we can make an impact
• We make detailed evaluations of our investees’ risk management related to sustainability and evaluates whether they are aligned with the “Do not significantly harm”-criteria according to the SFDR
• We track and measure the taxonomy alignment of our funds
• We exclude companies operating in the oil, gas and coal industry, i.e. companies with a share of total revenues from such activities exceeding 5%

• Companies involved in any environmental breaches will be assessed and based on the severity, set on our ESG Watchlist and excluded from our portfolios if not actions are taken.
• We complete regular ESG analyses of all our investees where the Environmental aspect is pivotal
• Executes consultation and engagement activities with our investees relating to ESG
• We measure our alignment with UN Global Compact and we follow up all our investees against Minimum Safeguards and monitors potential incidents
• We track what share of assets under management that is covered by Science Based Targets
• We gather information on our investees’ Scope 1, 2 and 3 emissions through our ESG questionnaire
• Two funds are currently classified as Article 9 according to the SFDR
• We source 100% renewable electricity for our premises
• In our annual ESG questionnaire we gather information on CO2 emissions, emission to water and hazardous waste-management and biodiversity impact

• Our funds are either classified as Article 8 or Article 9 funds according to SFDR, implying that we promote sustainability in our investments and that sustainability is an integral part of our investment process
• Our Anti-corruption policy states that we are not to engage in any form of corruption, follow all rules and guidelines against corruption and have routines to identify, measure, control and report on risks associated with corruption with regards to our size, structure and risk profile.
• Our Anti-corruption policy applies to our board members and employees and highlights our aim for our suppliers, partners and consultants to operate with similar anti-corruption guidelines and rules
• We assess the risk of corruption when doing business
• For our sustainable investments we require our holdings to comply with the Minimum Safeguards criteria (OECD Guidelines for Multinational Enterprises, UN Guiding Principles on Business and Human Rights and ILO core conventions)

• We require our investees to operate with good governance and to have rigorous policies on anti-corruption and anti-bribery relative to their size, structure and risk profile. We also require robust whistleblower-hotlines.
• Assessment of our investees and their risk exposure to corruption, money laundry and bribery
• We provide compulsory risk assessment training in regards to money laundry, bribery and corruption, how to detect and what to do, for our employees
• Risk-management function is with CEO and Head of Compliance

• Risk management function carries out internal audits to ensure consistency with anti-corruption commitment, including periodic review by senior management
• Monitoring of potential incidents of corruption both concerning the firm and investees
• In our regular ESG analyses of our investees, good governance, anti-corruption and risk management are key factors taken into consideration
• Companies involved in any breaches related to corruption or corporate governance will be assessed and based on the severity, set on our ESG Watchlist and excluded from our portfolios if not actions are taken