SFDR and Shareholder Engagement Policy

SFDR statement

19.01.2023 (v.1)

This statement is made in accordance with the EU Disclosure Regulation (2019/2088) regarding sustainability-related disclosures in the financial sector (the “SFDR”). The SFDR is applicable to Permian Fund Services AS (”PFS”) according to the Norwegian act of 22 December 2021 no. 161 on publication of sustainability information in the financial sector and a framework for sustainable investments.

Reference to articles below is a reference to articles in the SFDR.

Sustainability risk – article 3

According to article 2(22) of the SFDR, sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

PFS will take into account sustainability risks in its decision-making process by ensuring that potential portfolio investments are screened with regards to sustainability risks.

For some funds, the portfolio management is outsourced from PFS to a third party with separate license. Each such party have their own policy on how to address risks, including sustainability risks.

When portfolio management is outsourced, PFS’ role is to ensure that all applicable risks are taken into account in the decision–making process according to the portfolio manager’s policies.

No consideration of adverse impacts of investment decisions on sustainability factors – article 4

PFS does not consider adverse impacts of its investment decisions on sustainability factors. The reason for this is that PFS does not collect all information needed from portfolio investments in order to disclose adverse impacts on investment decisions in full. PFS intends to make a new assessment in due course.

Remuneration policy – article 5

In PFS’ capacity as fund hotel, where portfolio management has been outsourced, the integration of sustainability risk does not have an impact on the remuneration of PFS’ employees. In addition, employees of PFS does not have a variable compensation. For these reasons, sustainability is not included as an element in determination of remuneration to employees of PFS.

Product level disclosures – article 10

With reference to product (i.e. fund) level disclosures, we refer to the investor’s customary investor relations contact of the applicable fund.

Shareholder Engagement Policy

30.06.2023 (v.2)

In accordance with §4-7 of the Norwegian AIF Law (“the AIFM Act”), AIF Managers are to publish procedures describing their shareholder engagement in relation to their activity in shares admitted to trading on a regulated market that are registered in or operating in the EEA.

Permian Fund Services AS (“PFS”) is an AIFM that primarily manages funds investing in unlisted shares. As such, in line with the AIFM Act, PFS does not have a disclosure obligation when conducting such activity.

PFS is also the AIFM to funds that trade shares admitted to trading on regulated markets that are registered in or operating in the EEA. In such cases, the portfolio management which includes, inter alia, shareholder engagement, is delegated to licensed third-party managers (“Third-Party Managers”) who themselves have an obligation to publish their shareholder engagement policies.

As part of its oversight responsibilities, PFS is responsible for keeping up to date with legislative changes in this regard and will ensure that: a. Third-Party Managers are informed of any changes to applicable legislation with regards to shareholder engagement; b. shareholder engagement disclosure requirements in accordance with the AIFM Act are made publicly available by Third-Party Managers; and c. Third-Party Managers’ shareholder engagement policies are abided by.

As of the date of this policy, in-scope third-party managers consist of:
Hausta Kapitalforvaltning AS in respect of Hausta Investor AS.