Sustainability-related disclosures

SFDR Product-level disclosures

All MEI SFDR disclosures

SFDR Entity-level disclosures

Entity name: Norselab Investment Management AS
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 Meaningfulness Policy and the applicable product-specific pre-contractual disclosures. At the product level, prior to investment, the initial screening and sustainability due diligence consider aspects that are material from a financial materiality (“outside-in”) perspective, including:

  • Activities or conduct falling within the exclusion criteria set out in the Meaningfulness Policy and the product-specific pre-contractual disclosures;
  • Products, services, or business practices that may undermine the achievement of the SDGs;
  • Compliance with good governance practices;
  • Exposure to sustainability-related operational and regulatory risk.

The Company considers that companies contributing to the SDGs are better positioned to create long-term value for clients and stakeholders alike. Conversely, businesses not aligned with a fair, nature-positive, and climate-resilient economy may face transition, regulatory, reputational, and market risks that could negatively impact financial performance and valuation.

As such, any significant negative sustainability impacts or significant sustainability risks identified through the assessment of any of the aspects listed above constitute grounds for exclusion of a potential company from investment consideration.


Consideration of adverse impacts of investment decisions on sustainability factors


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 considers the adverse impacts of its investments in investee companies, as set out in the SFDR. Through a structured assessment process, we ensure that the issuers included in the investment universe do not cause significant harm to the sustainable investment objective. We use a combination of data disclosed by the relevant companies and data provided by third parties to assess Principal Adverse Impact indicators. We publish an annual statement for the previous reporting year for each fund by June 30th.


Sustainability risks integration in the 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 Meaningfulness 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.