Sustainability-related disclosures

SFDR Product-level disclosures

Norselab Sustainable High Yield Disclosures

Norselab Financial Hybrid Disclosures

Norselab Real Estate Credit Opportunities Disclosures

SFDR Entity-level disclosures

Entity name: Norselab Credit Management
Version date: 30.06.2026

Policy on the integration of sustainability risks in the investment decision-making process

Pursuant to Article 3 of Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (“SFDR”), the Company is required to publish information on its policies regarding the integration of sustainability risks in the investment decision-making process.

A sustainability risk is defined as an environmental, social, or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.

The Company integrates sustainability risks into investment decision-making, in line with its Responsible Investment Policy and the applicable product-specific pre-contractual disclosures.

The various mandates and funds may be exposed to sustainability risks from time to time. The universe of sustainability events or conditions is very broad, and their relevance, materiality, and impact on investments will depend on several factors. If they materialize, sustainability risks can reduce the value of investments held in funds managed by Norselab Credit Management and could have a material impact on the performance and returns of the respective funds.

Assessments of sustainability-related risks and, when relevant, opportunities are conducted using a data-driven screening process and/or qualitative assessments and are tailored to the sustainability profile of the financial product. This systematic process for assessing all investment cases offers pre-trade risk mitigation by ensuring that investment processes adhere to the present policy.

The approach to impact and sustainable investments (as defined in SFDR) is described in more detail in the relevant funds’ Annexes. In line with regulatory requirements, the Investment Manager publishes the annual disclosures for each fund by June 30 each year.

Considering Principal Adverse Impacts on sustainability factors in investment decisions

Pursuant to Article 4 of Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (“SFDR”), the Company is required to communicate whether it considers adverse impacts of investment decisions on sustainability factors, such as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

The Company does not currently consider the adverse impacts of its investment decisions on sustainability factors, as set out in Article 4 of the SFDR, at the entity level.

Lack of reliable ESG/PAI data from many portfolio issuers makes it difficult to implement a systematic and decision-useful approach to considering Principal Adverse Impacts. The cost and resource requirements for considering Principal Adverse Impacts are disproportionately high for smaller investment managers to secure sufficient quality of such considerations.

Sustainability risks integration in our Remuneration Policy

Pursuant to Article 5 of Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (“SFDR”), the Company is required to include in this Policy information on how the Policy is consistent with the integration of sustainability risks.

A “Sustainability Risk” refers to an environmental, social, or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.

Sustainability risks are integrated into the investment decision-making process in accordance with the Company’s Responsible Investment Policy and the relevant pre-contractual disclosures for the financial products managed by the Company.

The Company’s remuneration framework is designed to promote sound and effective risk management, including the management of sustainability risks, and does not encourage excessive risk-taking. The remuneration structure is balanced and primarily based on fixed remuneration, thereby reducing incentives to take excessive risks or make investment decisions that are inconsistent with the integration of sustainability risks.

Where variable remuneration is awarded, it is discretionary and is not specifically determined by reference to sustainability risk-related performance targets or indicators. The Company nevertheless requires employees, including members of the investment management team, to comply with its internal policies and procedures relating to the integration of sustainability risks and responsible investment practices.