General sustainability disclosures

The investment process will be carried out in order to fulfil the obligations of the investment mandate of the funds under management. If sustainability risks should be implemented in the investment mandate of the fund ACM will take the necessary steps to ensure compliance to this in the investment process.

For those situations that sustainability risks is not a part of the investment mandate such risks will not be a part of the investment decision process.

Updated 29.03.2023

Currently ACM does not consider principal adverse impacts, as described in article 4 of the SFDR, on sustainability factors as a consequence of investment decisions made.

We have come to this conclusion as we expect significant challenges in obtaining information of sufficient quality on a needed level of detail from our current and potential investment objects. The lack of quality and detail will prevent us from reporting meaningful figures on the principal adverse impact indicators set out in the regulatory technical standards accompanying the SFDR.

However, ACM will consider to report on principal adverse impacts if and/or when relevant information of relevant quality are available.

Updated 29.03.2023

Our remuneration policy aim to reduce the incentives to take excessive risk in the asset management process. Sustainability risks are not a part of the overall risks as implemented in the asset management agreement between ACM and the fund Altitude Capital AS.

Updated 29.03.2023

As the investment mandate of Altitude Capital do not include sustainability risks as parameter neither in the risk section nor in the limits section ACM has concluded that sustainability risks shall be exempted from the investment decision process.

At current ACM estimate that integration of sustainability risk in the investment process will reduce the potential investment universe, such restriction is believed by ACM to reduce the long-term return of the fund.

Updated 29.03.2023