ROSFELT ENTERPRISES AB’S SFDR & ESG POLICY

Our policy

Rosfelt Enterprises AB (“Rosfelt”) aims to generate superior risk adjusted returns to investors through the acquisition, development and subsequent divestment of companies that fit its investment criteria. Rosfelt believes that responsible investing is an integral part in achieving its objectives. Rosfelt defines responsible investment as an approach to investing that aims to incorporate ESG factors into investment decisions, to better manage risk and generate sustainable, long-term returns.

Rosfelt supports the UN’s sustainable development goals (SDGs) and believes that the following SDGs are particularly relevant for Rosfelt’ investment activities: Decent work and economic growth; Responsible consumption and production.

As part of its investment analysis, Rosfelt will seek to identify potential ESG risks and improvement areas, as well as potential ESG related value creation opportunities.  The assessment should generally include (but is not limited to): Evaluation of ESG related practices at the company; Natural resource consumption; Compliance with basic requirements for good working conditions; Risk of corruption, bribery and irregularities; Risk of contributing to human rights violations; Presence of controversial products and services; Dealings with countries under sanction.

A portfolio company’s board of directors is responsible for defining and implementing ESG related strategies and policies, subject to potential requirements set by Rosfelt. Such requirements may include: Define company specific ESG objectives and KPI:s; Appoint a person responsible for sustainability to coordinate the company’s activities; where required, ESG should be an agenda point on a board meeting at least once a year.

Rosfelt’s board is ultimately responsible for the implementation and follow-up of the Rosfelt ESG policy.

Rosfelt supports the Paris Agreement on Climate Change.

Article 3 disclosure

The integration of sustainability risks in the investment decision-making process

Rosfelt Enterprises AB (the “AIF Manager”), as part of its investment process and risk mitigation procedures, evaluates potential investments and monitor each investment across a spectrum of factors throughout its life time. The AIF Manager recognizes the need to consider sustainability risks, meaning environmental, social and governance (“ESG”) issues which, were they to occur, could have a material negative impact on the value of an investment, and may affect the risk-adjusted returns of an investment or a portfolio in different ways and to varying degrees depending on the specific investment. Where identified as relevant to an investment, sustainability risks are considered as one factor among a number of other factors and therefore forms part of the AIF Manager’ wider investment decision-making process. Factors may be identified as relevant at the outset as well as factors may become relevant due to changes in environmental or social conditions, changes in law or policy, market expectation, new information or research and other developments.

The significance of sustainability risks to the investment proposition is assessed in the context of the relevant underlying asset, including its overall risk and return profile. Other relevant considerations may include the level of intended or actual control or influence exercised by the AIF Manager over an investee company.

In identifying and assessing sustainability risks, the AIF Manager may use various methods, including (without limitation) investment analysis and direct engagement with investee companies and their management. As part of the investment analysis, the AIF Manager seek to identify potential sustainability risks. Sustainability risks analysed by the AIF Manager may include evaluation of risks relating to an investee company’s environmental practices; natural resource consumption; compliance with basic requirements for good working conditions; policies and procedures with respect to mitigating corruption, bribery and financial and other irregularities; compliance with human rights law; dealings in controversial products and services; and governance arrangements regarding dealings with countries under applicable sanction law. Where relevant, recommendations for improvements regarding the performance of an investee company in the above-mentioned areas may be incorporated into the pre-investment analysis.

The AIF Manager’s engagement with the management of investee companies varies depending on the level of control or influence exercised. The AIF Manager normally has a limited influence (as a minority or non-controlling holder) of an investee, but will seek, where appropriate and to the extent possible, to escalate sustainability risks to the management and/or majority owners to promote actions to resolve or mitigate applicable sustainability risks. Where applicable, the AIF Manager may require that investee companies set targets to seek to achieve in respect of sustainability matters, and seek to ensure that the sustainability performance and sustainability risk of the investee company are discussed by the company’s board at least annually.

Identification of one or more sustainability risks alone will not generally preclude the AIF Manager from pursuing an investment where such investment is otherwise assessed to meet the investment criteria, including where such sustainability risks can be appropriately monitored and managed. However, in circumstances where the sustainability risks are overwhelmingly detrimental to the potential performance of an investment, the AIF Manager may cease to pursue the opportunity further. The AIF Manager do not pre-emptively exclude specific investments, industries or sectors from consideration; instead, the AIF Manager evaluate each investment on its merits in light of all of the factors that it considers relevant.

The AIF Manager continue to monitor and adapt to prevailing market conditions and risks and may from time to time refine or modify its approach described above with respect to the integration of sustainability risks in response to such conditions and risks.

Article 4 disclosure

No consideration of sustainability adverse impacts

Rosfelt Enterprises AB (the “AIF Manager”) do not currently consider the principal adverse impacts of investment decisions on sustainability factors for the purposes of Article 7 of the SFDR as the detailed rules and guidance regarding such disclosure have not been formally adopted, and given the lack of accessible, relevant and comparable data. The AIF Manager will seek to adhere to market practices to the extent it is able to, and will regularly evaluate information available.

Article 5 disclosure

Alignment of the remuneration policy with respect to integration of sustainability risks

For the purposes of Article 5(1) of Regulation (EU) 2019/2088, remuneration at Rosfelt Enterprises AB (the “AIF Manager”) includes a range of factors that are considered in order to determine the appropriate level of remuneration for individuals. However, sustainability risk is not considered as a discrete and separate performance component but rather forms part of the wider assessment of the relevant individual’s contribution to the AIF Manager.