SFDR Article 4

No consideration of principal adverse impacts of investment decisions on sustainability factors

SFDR Article 4

SFDR article 4 requires AIFMs such as Hvitsten to publish and maintain on their websites information on whether they consider principal adverse impacts ("PAI") of investment decisions on sustainability factors and, if they do not consider PAI, clear reasons therefor, including, where relevant, information as to whether and when they intend to do so.

Sustainability factors are environmental, social and employee matters, respect for human rights, anticorruption and anti-bribery matters, and PAI are the most significant negative impacts of investment decisions on these factors.

As highlighted in the Sustainability Investment and Risk policy, Hvitsten is considering ESG factors in its investment management practices. However, Hvitsten does not consider adverse impacts of decisions on sustainability factors at entity level, within the meaning of Article 4 of the SFDR when making investment decisions, or assisting in connection with any such, as the case may be. Indeed, access to

relevant data is generally limited as reporting practices on PAI indicators are currently in the process of being implemented in private markets, including for infrastructure projects. This prevents systematic consideration of PAI at entity level. However, Hvitsten does consider PAIs in the management of Wind Fund I. Hvitsten will review the consideration at PAI at entity level as reporting practices develop.