No sustainable investment objective: This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment. (So called article 8 fund).

Environmental or social characteristics of the financial product: Nordkinn’s sustainability efforts shall create value for the Funds unitholders while at the same time promoting environmental and social characteristics. The sustainability efforts focus on the measures considered to have the greatest potential to promote environmental and social characteristics. By identifying, measuring, and assessing the opportunities and risks arising from the transition to a sustainable economy, and incorporating these opportunities and risks into interest rates and asset prices, conditions are created for investments to be channelled into impact towards more sustainable activities.

Since 2017, Nordkinn has systematically integrated sustainability considerations into its investment process, both to reduce the risk of potential adverse effects on the Fund’s returns and to limit principal adverse impacts on sustainability factors, as well as to promote positive environmental or social characteristics. This includes identifying, measuring, and pricing sustainability risks and opportunities in order to select appropriate investments; determining which activities Nordkinn does not wish to be exposed to based on such risks; and pursuing engagement strategies with issuers to which the Fund is exposed in order to promote positive development in relation to these sustainability factors.

Investment strategy: Manager’s strategy for value-creating sustainability work is driven on the premise to:

• be integrated in the investment process
• limit certain sustainability risks by excluding relevant sectors
• engagement through dialogue
• quantify objectives that can be measured and followed up
• drive change, adjustment, and management towards the objectives
• Nordkinn is signatory of the six principles of UN PRI since 2017

Proportion of investments: Nordkinn’s Sustainability policy includes both direct exposures in investee entities and all other types of exposures to those entities, and shall not account for less than 85 percent of the Fund’s total allocation.

Monitoring of environmental or social characteristics: Nordkinn’s Sustainability Committee and Risk Committee are responsible, within their respective areas of responsibility, for monitoring the Fund’s environmental and social characteristics, including relevant sustainability risks and adverse impacts on sustainability.

The Sustainability Committee is the governing body responsible for the implementation and monitoring of Nordkinn’s sustainability efforts. The Committee is responsible for defining, and on an ongoing basis evaluating and monitoring, the sustainability process, the sustainability indicators used to monitor the environmental and social characteristics promoted by the Fund, engagement themes, exclusion criteria, and internal and external ESG analysis.

The Risk Committee is responsible for continuously monitoring and evaluating sustainability risks in the Fund’s investments and their potential impact on the Fund’s risk profile and returns.

Methodologies: Nordkinn measures and assesses the extent to which the environmental or social characteristics promoted by the Fund are attained by analysing both the progress made towards the defined sustainability targets of the Fund’s investments and the development of relevant principal adverse impacts of the Fund’s investment decisions on sustainability factors. The analysis shall be based on data as at the most recent year-end and evaluated over time by the Sustainability Committee.

Data sources and processing: A combination of reported data collected by Nordkinn from the Fund’s investments, official national statistics, data from international organisations, and Bloomberg ESG data is used to monitor the environmental or social characteristics promoted by the Fund.

Limitations to methodologies and data: The primary limitations relate to the ability to set relevant expectations regarding the pace of the transition towards the sustainability objectives, as the work involved is in many cases complex and requires significant resources and, in some cases, the development or application of new technologies.

Another limitation relates to the quality, and consequently the reliability, of the data collected. Several sustainability factors remain difficult and complex to measure and require significant resources to calculate. As a result, the proportion of data that is estimated remains high.

Due diligence: Nordkinn applies due diligence procedures to ensure that sustainability risks and the Fund’s sustainability requirements are considered throughout the investment process. This includes ongoing screening of all holdings against Nordkinn’s exclusion criteria, oversight by the Sustainability Committee, and continuous monitoring of sustainability risks by the Risk Committee.

Engagement policies: Nordkinn seeks to exercise influence through direct engagement with issuers financed through the Fund’s investments. The Sustainability Committee is responsible for defining engagement themes based on the areas in which Nordkinn is considered to have the greatest potential to positively influence sustainability factors. The purpose of the engagement with issuers is to encourage them to establish defined targets for the transition towards sustainability, appropriate strategies and resources for alignment with sustainability objectives, and to measure and report their progress in a reliable, transparent and accessible manner.

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective. The promotion of environmental or social characteristics by the Fund includes, among other things, taking into account environmental and climate-related considerations, as well as human rights, labour rights and equal treatment.

Nordkinn’s sustainability efforts shall create value for the Fund’s unitholders while at the same time promoting environmental and social characteristics. The sustainability efforts focus on the measures considered to have the greatest potential to promote environmental and social characteristics. By identifying, measuring and pricing the opportunities and risks arising from the transition to a sustainable economy, and incorporating these opportunities and risks into interest rates and asset prices, conditions are created for investments to be channelled towards more sustainable activities.

The Fund promotes environmental characteristics in accordance with the EU Taxonomy and the Paris Agreement, with a focus on climate change mitigation and the protection and restoration of biodiversity, through:

• Investments that are considered to contribute to the environmental objectives of the United Nations Sustainable Development Goals under the 2030 Agenda, the Paris Agreement and the environmental principles of the United Nations Global Compact.
• Exclusion criteria for activities related to fossil fuels, as well as activities that breach international norms and conventions relating to environmental matters.
• Consideration of principal adverse impacts in relation to climate- and other environment-related indicators.
• Engagement with issuers on environmental matters.

The Fund promotes social characteristics, with a focus on compliance with the United Nations Global Compact and the OECD Guidelines for Multinational Enterprises, with the aim of promoting fair wages, greater gender balance on boards, and efforts to combat corruption and bribery, money laundering and terrorist financing. This is achieved through:

• Investments that are considered to contribute to the social objectives of the United Nations Sustainable Development Goals under the 2030 Agenda.
• Exclusion criteria for activities related to corruption, controversial weapons, alcohol, tobacco, commercial gambling, pornography and cannabis for non-medical use, as well as activities that breach international norms and conventions relating to social matters, including the United Nations Global Compact and its Ten Principles concerning human rights, labour and anti-corruption, the OECD Guidelines for Multinational Enterprises, the International Labour Organization (ILO) standards, and the United Nations Guiding Principles on Business and Human Rights.
• Consideration of principal adverse impacts relating to social and employee matters, respect for human rights, and anti-corruption and anti-bribery matters.
• Engagement with issuers on social matters.

The Fund is actively managed and pursues a global macro fixed income strategy with the objective of generating absolute returns with low correlation to traditional asset classes (equities and bonds). The Fund invests in transferable securities, money market instruments, derivative instruments and deposits with credit institutions. The Fund also holds cash for liquidity management purposes.

The Fund invests in financial instruments with a primary focus on the Nordic capital markets and other OECD markets. At least 50 per cent of the Fund’s value shall at all times be invested in interest rate-related financial instruments. The Fund’s investment strategy is otherwise not restricted to any particular sector or to financial instruments issued by any particular issuer or similar limitation. The allocation between asset classes varies over time.

Nordkinn’s sustainability efforts shall create value for the Fund’s unitholders. Investments shall be made in a manner that promotes environmental and social characteristics and limits sustainability-related risks, without at the same time causing significant harm.

Analysis of sustainability factors: Nordkinn’s Sustainability Committee is responsible for continuously identifying and prioritising adverse impacts on sustainability factors and for keeping such selections and priorities up to date. The assessment considers which sustainability factors are most likely to occur or to cause significant harm if they occur. The assessment also considers which factors may have the greatest adverse impacts in light of the initiatives and sustainability objectives to which Nordkinn has committed. The methodology applies the principle of proportionality, taking into account the investments made by the Fund.

Exclusion strategy: The Fund applies sustainability requirements in the form of an exclusion strategy. This means that the Fund refrains from investing in issuers that violate international norms and conventions. This includes, among other things, human rights, labour rights and international law, corruption and financial crime, serious climate and environmental harm, deforestation, and controversial weapons (anti-personnel mines, cluster munitions, and chemical and biological weapons). The Fund also excludes sovereigns that do not meet the minimum threshold defined by Nordkinn under Transparency International’s Corruption Perceptions Index (CPI). With respect to the Fund’s investments in investment objects, which are limited to Kommuninvest and covered bonds issued by credit institutions, the exclusion criteria also cover activities related to tobacco, weapons, alcohol, gambling, pornography, cannabis, fossil fuels (coal, oil and gas), and oil sands.

Engagement: For sovereigns, municipalities and covered bonds to which the Fund is exposed, potential adverse impacts on sustainable development are assessed through data collection and analysis. In relation to environmental characteristics, social characteristics and governance matters where Nordkinn considers that it has the potential to exercise a positive influence, Nordkinn shall, through active engagement, seek to encourage the sovereigns, municipalities and issuers of covered bonds to which the Fund is exposed to have ambitious targets for the transition towards sustainability, appropriate strategies and resources for the transition, and to measure and report their progress in a reliable, transparent and accessible manner.

Good governance practices: Nordkinn shall assess the good governance practices of investee companies, including with respect to sound management structures. This is carried out through due diligence on the investments and includes, among other things, obtaining relevant data through Nordkinn’s own data collection and direct communication with mortgage credit institutions, as well as through Nordkinn’s external ESG data providers. This includes, among other matters, assessing the unadjusted gender pay gap, gender diversity on boards and the investee companies’ approach to bribery, corruption and money laundering.

Nordkinn’s strategy for value-creating sustainability efforts is implemented by:

• integrating sustainability considerations into the investment process;
• limiting certain sustainability risks through the exclusion of relevant sectors;
• engaging through dialogue;
• quantifying objectives that can be measured and monitored;
• driving change, transition and governance towards the quantified objectives; and
• being a signatory to the six Principles for Responsible Investment (PRI) since 2017.

The Fund invests in sovereign securities, municipalities, covered bonds and currencies. Investments are made both through direct exposures to issuers and through other types of exposure, including various types of derivatives. Nordkinn’s policy for promoting environmental or social characteristics applies both to direct exposures to issuers and to all other types of exposure to such entities.

For liquidity and risk management purposes, the Fund may hold cash and cash equivalents. No minimum environmental or social safeguards apply to this allocation. Cash and cash equivalents shall never account for more than 15 per cent of the Fund’s total allocation.

Nordkinn’s Sustainability Committee is the governing body responsible for the implementation and monitoring of Nordkinn’s sustainability efforts. The Sustainability Committee consists of five members, two of whom are external members with extensive experience in sustainability matters, thereby providing Nordkinn with additional expertise and value in these areas. The Sustainability Committee meets quarterly and, in addition, as required.

Nordkinn shall seek to limit risks that could cause, contribute to or be directly linked to principal adverse, significant or potentially significant impacts on the sustainability transition. The sustainability efforts focus on the measures considered to have the greatest potential to contribute positively across three sustainability factors: environmental, social and governance factors.

Through the ongoing collection of data on sustainability indicators, the Fund’s investments are continuously monitored to ensure that the environmental and social characteristics are attained. Sustainability factors are screened annually and, where deviations are identified, the relevant investment is placed under enhanced monitoring. The monitoring also ensures that the Fund does not invest in excluded activities.

The following sustainability indicators relating to principal adverse impacts are considered when assessing the attainment of each of the environmental or social characteristics promoted by the Fund:

Environmental characteristics: greenhouse gas emissions of the Fund’s investments, adverse impacts on biodiversity, water and waste, the share of investments without carbon emission reduction initiatives, and the share of investments in entities active in the fossil fuel sector.

Social characteristics: the share of investments in entities that have been involved in violations of, or lack policies to monitor compliance with, the United Nations Global Compact or the OECD Guidelines for Multinational Enterprises; the unadjusted gender pay gap; gender diversity on boards; exposure to controversial weapons; companies without policies to combat corruption and bribery; and companies without policies to combat money laundering and terrorist financing.

The Sustainability Committee is responsible for continuously monitoring the definition of the exclusion criteria, analysing the results of the screening process on an ongoing basis and approving investments for exclusion. The Sustainability Committee is further responsible for defining engagement themes in areas where Nordkinn is considered to have the greatest potential to influence sustainability matters, identifying the most appropriate approach to such engagement, and identifying other sustainability activities that support Nordkinn’s efforts from both an investor and a broader societal perspective.

Information on indicators of adverse impacts on sustainability is identified and evaluated on an ongoing basis, at least annually. The extent to which the environmental or social characteristics promoted by the Fund are attained is assessed by analysing both progress towards the defined sustainability objectives of the Fund’s investments and the development of relevant principal adverse impacts of the Fund’s investment decisions on sustainability factors. The monitoring also ensures that the Fund does not invest in excluded investments.

Where considered relevant, Nordkinn follows up with issuers to understand the underlying reasons where there has been no positive progress towards sustainability objectives or reduction in adverse impacts on sustainability factors for more than one reporting period. Nordkinn assesses whether the explanation provided is acceptable and, where it is not considered acceptable, determines the appropriate measures to be taken.

A combination of Bloomberg ESG data, official national statistics, data from international organisations and data obtained directly from the Fund’s investments is used to monitor the environmental or social characteristics promoted by the Fund. The information includes exposure to excluded activities, incidents involving breaches of international norms and conventions, and information on indicators of adverse impacts on sustainability.

To ensure data quality, Nordkinn performs its own checks of the data obtained against data reported by the relevant issuers, including in annual reports and sustainability reports, and, where considered relevant, against information obtained directly from the issuer or from other external sources. Where necessary, Nordkinn also engages with the external data provider to ensure the quality of the data.

The data is analysed by Nordkinn’s Sustainability Committee and evaluated against objectives defined by Nordkinn and the relevant issuers, as well as internationally established objectives such as those of the Paris Agreement. Deviations are evaluated over time.

The proportion of estimated data remains high for several sustainability factors, such as greenhouse gas emissions. Nordkinn expects the proportion of estimated data to decrease over time.

The primary limitations relate to the ability to set appropriate expectations regarding the pace of progress towards the objectives, as the work involved is in many cases complex and requires significant resources and, in some cases, new technologies. Another limitation relates to the quality, and consequently the reliability, of the data collected. Several sustainability factors remain difficult and complex to measure and require significant resources to calculate. As a result, the information available in certain areas remains limited and is partly based on estimates. A significant amount of data is also reported and collected with a considerable time lag, which constitutes an additional limitation.

By following up with issuers and analysing the reasons for any deviations in progress towards the objectives, Nordkinn can determine appropriate measures to reduce the risk that these limitations affect the attainment of the environmental or social characteristics. To minimise the risk of using incorrect data, Nordkinn performs checks against data reported by issuers in their annual reports or sustainability reports, as well as against other available sources, and engages in dialogue with issuers and external data providers. To address the significant time lag in reporting, Nordkinn uses the most up-to-date information available.

Nordkinn has due diligence procedures in place to ensure that sustainability risks and the sustainability requirements established for the Fund are taken into account in the investment process. As part of this process, all of the Fund’s holdings are subject to ongoing screening against Nordkinn’s exclusion criteria. The screening is carried out using information from external data providers and other relevant sources of information.

Nordkinn’s Sustainability Committee is responsible for defining, continuously evaluating and monitoring the sustainability process. This includes identifying and assessing relevant sustainability risks and principal adverse impacts on sustainability factors, as well as following up on the ongoing screening. The Sustainability Committee is also responsible for assessing whether an issuer should be excluded where identified sustainability risks or adverse impacts are considered unacceptably high and engagement or other stewardship measures are not considered likely to result in sufficient improvement within a reasonable period of time.

Nordkinn’s Risk Committee is responsible for continuously monitoring and evaluating sustainability risks in the Fund’s investments and their potential impact on the Fund’s risk profile and returns, as well as ensuring that sustainability risks are taken into account as part of Nordkinn’s overall risk management framework.

Nordkinn does not invest in equities and is therefore unable to exercise influence by voting on matters at general meetings or by participating in nomination committees. Instead, Nordkinn seeks to exercise influence through direct engagement with issuers that Nordkinn finances through investments in fixed income securities. The Sustainability Committee is responsible for defining engagement themes based on the areas in which Nordkinn considers that it has the greatest potential to positively influence sustainability factors.

Nordkinn’s engagement strategy also covers investments in securities issued by sovereigns to which the Fund has exposure. As part of this approach, Nordkinn may engage in dialogue with relevant sovereign representatives in order to deepen its understanding of, and follow up on, matters relevant to the environmental and social characteristics promoted by the Fund. Such dialogues may address, among other things, sovereign climate targets, the implementation of international commitments and other sustainability-related matters considered relevant to the Fund’s investments.

Where Nordkinn considers that it has the potential to positively influence environmental, social and governance characteristics, it initiates dialogue with the aim of encouraging the issuer to establish ambitious targets for a sustainable transition, have a strategy and adequate resources in place to achieve those targets, and measure and report its progress in a high-quality, transparent and accessible manner.

Nordkinn’s external ESG consultant provides monitoring and reporting of identified sustainability-related controversies, such as breaches of the UN Global Compact or the OECD Guidelines for Multinational Enterprises. In such cases, Nordkinn may choose to engage directly with the issuer where it considers that such dialogue could contribute to a positive outcome. Nordkinn may also choose to divest the investment if the issuer fails to take appropriate measures to address the identified issues, or where Nordkinn’s Sustainability Committee determines that the issuer is unlikely to resolve the issues within a timeframe considered reasonable by Nordkinn in the circumstances of the individual case.

The results of Nordkinn’s sustainability activities are presented in detail as part of the Fund’s annual report.

The Fund is actively managed and has an absolute return objective. No index is used to determine whether the Fund attains the environmental and social characteristics it promotes.

30 June 2026

Nordkinn’s engagement strategy was expanded to also include investments in securities issued by sovereigns to which the Fund has exposure.