Sustainability disclosures

Sustainability risk policies

At Northern Horizon Capital A/S and its subsidiaries (“Northern Horizon”) we acknowledge that our real asset activities affect the society and environment around us. Consequently, we have integrated sustainability factors into our investment decision‐making process. By sustainability we mean environmental, social and governance (“ESG”) dimensions of our investment activities.

Northern Horizon has adopted two policies to ensure that sustainability risks are considered in a consistent and coherent manner in connection with all investment decisions. The cornerstone of our sustainability evaluations is our Responsible Investment Policy, which is complemented by our Portfolio Management Policy. Our remuneration policy is also aligned with our Responsible Investment Policy so as to support taking sustainability factors into account in our investment decision‐making process.

According to our policies, sustainability factors and associated risks are considered as part of the due diligence process on targeted investments and the summary conclusion provided as part of the investment proposal. The sustainability factors covered in connection with investment decisions include, but are not limited to:

• Assessment of energy performance – energy supply and access to renewable energy, sources of energy consumption data, energy ratings, building certification, emissions and other relevant topics
• Assessment of environmental aspects – building materials, contamination, water efficiency, water supply, waste management and other relevant topics
• Assessment of social aspects – building safety, indoor environmental quality, health and wellbeing, green clause provisions, tenant and landlord ESG collaboration, other relevant topics
• Risks associated with new construction and renovations – site selection, biodiversity, developer selection, waste management, building materials and other relevant topics
• Other topics – access to transport links, regulatory risks, review of climate change related transition, physical and social risks

Responsible Investment Policy

No consideration of sustainability adverse impacts

Northern Horizon is committed to strive for sustainability at all levels of its operations and is a member of INREV, SIPA and GRESB, as well as a signatory of the United Nations-supported Principles for Responsible Investment.

Despite this, however, Northern Horizon does not at this point consider adverse impacts of investment decisions on sustainability factors as laid out in Article 4(1) of SFDR. There are two main reasons for this decision. Firstly, the data currently available is insufficient to fulfil the requirements which are expected to arise from the technical standards complementing SFDR. Secondly, Northern Horizon believes that it can continue acting in a sustainable manner utilizing its aforementioned policies and methods and resources currently available. However, Northern Horizon will re-evaluate, whether it shall consider adverse impacts of investment decisions on sustainability factors once the final contents of the technical standard are available and on a regular basis thereafter.

Remuneration policy

Northern Horizon has adopted a remuneration policy, which reflects the Group’s objectives for good corporate governance, sustained and long- term value creation for investors and shareholders of the Group, as well as the sustainability objectives.

According to the policy, when assessing individual performance of an identified staff member and all other employees, financial as well as non-financial criteria shall be taken into account. The non-financial criteria, can include, but are not limited to ESG specific criteria relevant to an individual fund and / or the Group. Also, the Board of Directors may, in respect of deferred variable remuneration, decide to cancel the payment of the remuneration in whole or in part. This might apply as an example when business objectives are not achieved, including but not limited to ESG objectives.