General sustainability disclosures

For AC Management AS & Altitude Capital AS

The purpose of this document is to disclose how AC Management AS (“ACM”) at current act in relation to the obligations of SFDR.

Article 3 – Sustainability policies in the investment process

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 29.02.2025

Article 4 – Principal adverse impacts

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 29.02.2025

Article 5 – Remuneration policy

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 29.02.2025

Article 6 – Transparency of the integration of sustainability risks at product level – Altitude Capital AS

Transparency of the integration of sustainability risks at product level – Altitude Capital AS.

As the investment mandate of Altitude Capital do not include sustainability risks ACM addresses sustainability risk broadly by assuming that the financial markets value companies with good sustainability processes such that these companies will outperform the market and be viewed more favourably by analysts. Conversely, ACM assumes companies without such processes will be unpopular with both the market and analysts. Given regulatory requirements, ACM has developed its own approach to specific sustainability factors in the investment DD process.

ACM has selected 2 factors within each of the 3 ESG areas:

Environment

  • Significant environmental obligations or cleanup responsibilities
  • Substantial exposure to regulatory climate requirements/taxes

Social

  • Significant HSE risks in operations
  • Dependence on suppliers in high-risk countries, defined as countries with ITUC rating of 5+

Governance

  • Overall transparency in ownership and governance structure
  • Identified history of corruption in the company

These factors will be included in the DD process for all new investments, using company specific information and other relevant sources. Assessment may be completed after investment if the position is liquid and can be divested without significant cost.

Sustainability Risk Framework for the Fund

The main principle is that sustainability risk should not drive the investment process unless the expected impact from such events from each investment would negatively affect fund returns by more than 5% annually. This should be interpreted in a way such as, if measured sustainability factors occur with consequences resulting in negative returns of 5% on the overall fund, the investment should not be made or should be divested if occurring during ownership.

Updated 29.02.2025