Transparency of sustainability risk policies (Article 3)
We integrate ESG-related threats into all our active investment strategies within Infrastructure investments but not within Private Equity investments. Based on ESG research, we adjust, for example, future earnings, future write-downs of the assets’ values and/or change the risk premium that we require in our investment calculations.
We also work actively with companies that we believe should or have the potential to reduce their sustainability risk. In this way, we can assist companies in reducing their sustainability risk, concurrently reducing the risk in our investments. If the sustainability risk is perceived to be too great and/or the companies are not willing to adjust their sustainability risk exposure, Obligo will refrain from investing in such companies.
No consideration of adverse impacts of investment decisions on sustainability factors (Article 4)
Article 4 of the SFDR provides a framework designed to provide transparency in relation to the adverse impacts of investment decisions on sustainability factors. Financial market participants, such as Obligo, are required to indicate whether they consider the adverse impacts of investment decisions on sustainability factors. And, if so, to disclose certain related information in accordance with the requirements of the Regulatory Technical Standards (“RTS”) providing a detailed specification for the content, methodology and presentation of the information required to be disclosed.
Obligo has a long-standing commitment to active stewardship, including the consideration of ESG issues, in relation to its investments and maintains processes aligned with this commitment across its investment strategies. Further, Obligo is committed to developing its investment processes to maintain best practices as they evolve across the industry for investment in the asset classes that we invest in.
At the present time, Obligo does not, when making investment decisions, consider the adverse impacts of decisions on sustainability factors within the meaning of Article 4 of the SFDR as we consider that the information reported to us in relation to the portfolios to which we provide services does not enable us to do so. Obligo will keep its position in this respect under review as reporting practices develop. We may adopt the Article 4 framework in the future if we consider that to be practical and appropriate to do so, including being able to meet the requirements of the RTS.
December 22nd. 2022
Transparency of remuneration policies in relation to the integration of sustainability risks (Article 5)
Scope
Obligo has established a remuneration policy (the “Policy”) to comply with the AIFMD legislation in the Norwegian AIF regulation chapter 4. This Policy is applicable to all employees of OIM and possible entities owned or controlled by OIM. It is an arrangement for all functions within the Company. The Company’s employees have been made aware of the Policy after the Policy have been approved by the board of OIM
Guidelines
The Policy shall promote good and effective risk management and asset management in accordance with the investment mandates for the funds that are managed and must be adapted to the nature and scope of the business complexity. The Policy shall otherwise be in accordance with the Company’s and the funds’ business strategy, overall goals, risk tolerance and long-term interests. The Policy shall not encourage risk taking that is incompatible with the risk profile, the articles of association or other founding documents for funds under management. It is important to protect customers’ interests, avoid conflicts of interest and risk-taking that are incompatible with the risk profile, the articles of association or other founding documents for funds under management. To ensure that these considerations are taken into account, it is based on a practice that substantiates parallel interests between employees, customers and OIM. The integration of sustainability risks is part of the total risk assessment of the investments for funds under management and is hence included in all risk references in the Policy.
Individual assessments
The Policy allows employees to receive both fixed and variable remuneration. The fixed part of the remuneration is sufficient in the context that the company can abstain to pay variable remuneration. The variable part of the remuneration is awarded on the basis of achievement of individual objectives, compliance with laws and regulations, compliance to the risk profiles – including sustainability risks, as well as the results of the individual business unit, fund under management and the Company as a whole.
Procedures
The Company has made a proportionality assessment of the size of the management company and funds under management, the Company’s internal organization and the nature, purpose and complexity of its activities and based on this decided that the Company shall not to appoint a separate remuneration committee.
December 12th. 2022
