Sarsia Fond III AS

Website Disclosure under Article 10 SFDR
(Prepared in accordance with Articles 24–36 of Commission Delegated Regulation (EU) 2022/1288)

1. Summary

This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.

Sarsia Fond III AS promotes environmental and social characteristics through ESG integration, impact measurement and exclusions.The Fund commits to making a minimum share of sustainable investments with an environmental objective, mainly in activities not aligned with the EU Taxonomy.The Fund does not use derivatives and does not designate a reference benchmark.

This disclosure is consistent with the Fund’s pre-contractual SFDR disclosure dated 29 June 2024 and is reviewed annually.

2. No sustainable investment objective

This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.

The Fund nevertheless commits to making sustainable investments with an environmental objective. These investments are assessed to ensure they do not significantly harm any environmental or social objective.This includes considering the principal adverse impact indicators in Annex I of the SFDR RTS, adapted to early-stage companies as described in Tables 1 and 2 in the Fund’s pre-contractual disclosure .

All sustainable investments must align with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, including the ILO core conventions and the International Bill of Human Rights.

3. Environmental or Social Characteristics of the Fund

The Fund promotes:

• Investment in a minimum of 70% Impact-Driven Enterprises (IDE), each required to set 1–5 quantitative KPIs linked to their environmental or climate objectives.
• Systematic integration of ESG principles in screening, due diligence and investment decisions.
• Measurement and improvement of ESG factors during the investment period, including GHG emissions, energy use, waste, employee well-being and diversity.
• Exclusions: direct investments in fossil fuels extraction, weapons, tobacco, adult entertainment, gambling, and companies breaching UN Global Compact principles.

4. Investment strategy

The Fund invests in early-stage companies in Energy, Technology, Environmental Solutions and the Blue Economy that address sustainability challenges and demonstrate measurable impact potential.

Binding elements:

• ESG screening and due diligence;
• ESG documentation and improvement plans;
• ESG and impact commitments included in shareholder agreements;
• Annual ESG and impact reporting by IDEs.

Good governance is assessed through policies and practices on pay, management structure, tax compliance, ethics, anti-corruption, AML, data protection and board composition.

5. Proportion of Investments

• 100 % of investments promote environmental or social characteristics.
• ≥ 50 % of investments are sustainable investments with an environmental objective, not aligned with the EU Taxonomy.
• 0 % Taxonomy-aligned or socially sustainable investments.
• 0 % in transitional or enabling activities.
• No investments fall under “#2 Other.”

6. Monitoring of Environmental or Social Characteristics

The Investment Manager monitors attainment through annual ESG and Impact reporting

• Tracking Impact Goals (IGs), Target Values (TVs), Impact Multiples (IMs) and Overall Impact Goals (OIGs);
• Annual Portfolio Impact Goal (PIG);
• Annual ESG survey and assesment;
• Annual governance assessments;
• Monitoring compliance with exclusion criteria.

7. Methodologies

Methodologies include:

• The Knowledge Project (TKP) framework for ESG scoring;
• KPI and impact-tracking methodology form EIF;
• Annual measurement of GHG emissions, waste, diversity and employee well-being;
• DNSH and PAI assessments for sustainable investments using materiality-adapted indicators.;

8. Data Sources and Processing

The Fund uses:

• Primary data from portfolio companies through annual ESG and impact reporting;
• Verification through active ownership and board participation;
• Estimated values and sector benchmarks where full data are not available for early-stage companies.Data are processed by the Investment Manager for completeness, consistency and plausibility.

9. Limitations to Methodologies and Data

Limitations include:

• Incomplete ESG data for early-stage companies;
• Reliance on estimates or modelled data;
• Variable maturity in reporting systems.

These limitations are mitigated through annual follow-up, improvement plans and continuous engagement with portfolio companies.

10. Due Diligence

ESG due diligence includes:

• Screening against ESG criteria and exclusions;
• Assessment of PAI indicators and DNSH risks;
• Materiality assessment (“double materiality”);
• Establishment of baselines and KPIs;
• Requirement of mitigation measures or improvement plans.

11. Engagement Policies

Engagement is carried out through:

• Board participation and strategic dialogue;
• Follow-up of ESG action plans;
• Establishing ESG functions in portfolio companies;
• Annual monitoring of governance practices and policy breaches;
• Promoting compliance with UN Global Compact, OECD Guidelines and UNGP.

12. Designated Reference Benchmark

No reference benchmark is designated.

13. Additional Information

This information is kept up to date and reviewed annually or whenever a material change occurs. Pre-contractual (Annex II) and periodic (Annex IV) disclosures here:

• Pre-contractual (Linked documents)
• Periodic (Linked documents)

Prepared by Sarsia Management AS for Sarsia Fond III AS in accordance with Article 10 SFDR and Articles 24–36 of Commission Delegated Regulation (EU) 2022/1288.

Sarsia Seed Fond II AS

Website Disclosure under Article 10

1. Summary

This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.

Sarsia Seed Fond II AS (the “Fund”) is classified as a financial product referred to in Article 8(1) SFDR.The Fund promotes environmental and social characteristics through ESG integration, active ownership and exclusions, but it does not commit to making sustainable investments as defined in Article 2(17) SFDR.The Fund does not designate an index as a reference benchmark.

This information is consistent with the Fund’s pre-contractual disclosure dated 28 June 2024 and is kept up to date.

2. Environmental or social characteristics of the fund

The Fund promotes the following environmental and social characteristics:

Integration of ESG principles

All investments are selected based on an ESG due-diligence and subsequent analysis forming part of the Investment Manager’s investment decision process.

Measurement and improvement of ESG performance

Throughout the holding period, portfolio companies are monitored and encouraged to improve on:

• greenhouse gas emissions, energy management, waste generation and sustainability-related risk management,
• employee well-being, diversity and equal opportunity, health and safety, employee development, animal welfare and bioethics.

Exclusions

The Fund excludes companies outside the Fund’s thematic area and companies involved in:direct fossil fuels, weapons, tobacco, adult entertainment, gambling, and companies breaching the UN Global Compact principles.

3. Investment Strategy

The Fund invests in early-stage companies in the life sciences, renewable energy and technology sectors that develop innovative technologies with compelling value propositions.The portfolio is already established. Remaining investments are follow-on investments in existing companies to scale and prepare for exit. 

Binding elements of the strategy

To attain the promoted characteristics, the Investment Manager applies:

• ESG screening and due-diligence: systematic assessment of potential ESG impacts and company risks using The Knowledge Project (TKP) framework.
• ESG documentation and improvement plans: investees must provide relevant ESG documentation; improvement plans are required as necessary.
• Investment terms: ESG commitments and reporting obligations are included in shareholder agreements.
• Ongoing ESG involvement: ESG findings form the basis for action plans; the Manager assists companies in establishing ESG functions and follows up through board participation and periodic reporting.

Good governance practices

Good governance is assessed before and during the investment period, including:pay practices, management structures, tax compliance, business ethics, anti-corruption and AML, data privacy, board composition and operating rules. Annual governance assessment is performed using the TKP framework. 

4. Proportion of Investments

• The Fund intends to allocate 100 % of investments to attain the environmental and social characteristics it promotes.The Fund does not commit to any sustainable investments as defined by SFDR and therefore has:
• 0 % Taxonomy-aligned investments,
• 0 % sustainable investments,
• 0 % socially sustainable investments,
• 0 % transitional or enabling activities.
• No investments fall under “#2 Other”.

5. Monitoring of Environmental or Social Characteristics

The Investment Manager monitors attainment through:

• annual ESG measurement under the TKP framework,
• year-on-year comparison of GHG emissions, waste, energy use and social indicators,
• monitoring of exclusion breaches (target: 0 %),
• annual governance assessments including breaches of policies and regulations,
• ESG action plans and company reporting obligations.

6. Methodologies

The Fund uses the following methodologies to measure attainment of E/S characteristics:

• ESG scoring under The Knowledge Project (TKP) coordinated industry model,
• bespoke indicators for emissions, waste, diversity and well-being,
• qualitative assessment of progress on ESG action plans,
• measurement of exclusion breaches (aiming at 0 %).

The Fund does not carry out DNSH or PAI assessments for sustainable investments, as it does not commit to making them.

7. Data Sources and Processing

The Fund uses:

• Primary data from portfolio companies through annual ESG and impact reporting;
• Verification through active ownership and board participation;

Estimated values and sector benchmarks where full data are not available for early-stage companies.Data are processed by the Investment Manager for completeness, consistency and plausibility.

8. Limitations to Methodologies and Data

Limitations include:

• Incomplete ESG data for early-stage companies;
• Reliance on estimates or modelled data;
• Variable maturity in reporting systems.

These limitations are mitigated through annual follow-up, improvement plans and continuous engagement with portfolio companies.

9. Due Diligence

The Manager conducts ESG due-diligence before any investment, assessing:

• ESG risks and opportunities,
• potential impact on society and nature,
• screening against exclusion criteria,
• documentation of ESG policies and practices.

Findings inform the ESG action plan and reporting requirements post-investment.

10. Engagement Policies

The Investment Manager engages actively with portfolio companies through:

• board participation,
• follow-up of ESG action plans,
• establishment of ESG functions in portfolio companies,
• periodic ESG reporting,
• follow-up on governance breaches and improvements.

The Manager promotes alignment with UN Global Compact principles through active ownership.

11. Additional Information

This information is kept up to date and reviewed annually or whenever a material change occurs. Pre-contractual (Annex II) and periodic (Annex IV) disclosures here:

• Pre-contractual (Linked documents)
• Periodic (Linked documents)

Prepared by Sarsia Management AS for Sarsia Seed Fond III AS in accordance with Article 10 SFDR and Articles 24–36 of Commission Delegated Regulation (EU) 2022/1288.

Sarsia Seed Fund I

Sustainability-related information – SFDR Article 6

This financial product does not promote environmental or social characteristics and does not have sustainable investment as its objective, in accordance with Article 6 of the SFDR.

Sarsia Fond I AS was established in 2006 and is now in the final phase of its fund lifecycle.Sustainability risks are assessed as part of the general risk management, but they are not expected to have a material impact on the fund’s remaining investments.