SFDR Entity-Level Disclosures (Articles 3, 4 and 5)

Article 3 – Transparency of sustainability risk policies

Sarsia Management AS integrates sustainability risks into all investment decision-making processes. Sustainability risks are defined as environmental, social or governance events or conditions which, if they occur, could cause a material negative impact on the value of an investment.

Assessment of sustainability risks is embedded in:

• Initial screening, using sector-relevant ESG criteria and exclusion principles;
• ESG due diligence, evaluating environmental performance, social factors, governance structures and potential adverse impacts;
• Investment decisions, where sustainability risks are considered alongside traditional financial and operational risks;
• Active ownership, including board engagement, periodic ESG follow-up and support for improvement measures.

The approach is proportionate to company size, stage and available data, which is particularly important for early-stage venture companies. Sustainability risks may lead to adjusted valuations, additional mitigation requirements, or exclusion of a potential investment.

Article 4 – Principal adverse impacts (PAI)

Statement on the Non-Consideration of Principal Adverse Impacts

Sarsia Management AS does not consider principal adverse impacts of investment decisions on sustainability factors at the entity level, in accordance with Article 4(1)(b) of the SFDR.

The reasons for not considering PAIs are:

• the Investment Manager operates early-stage venture capital funds where portfolio companies are typically small, unlisted, and in early development stages with limited availability of reliable PAI-level data;
• given the nature of the investment universe, it is the Manager’s assessment that collecting, aggregating and reporting PAI indicators at entity level would not provide meaningful or decision-useful information;
• resources are better directed toward company-specific ESG risk assessment, screening, exclusions and active ownership, which are more effective tools in the context of early-stage venture investing.

Although PAIs are not considered at entity level, selected PAI indicators are used at fund level (e.g., for Sarsia Fond III AS) as part of screening, DNSH assessment and ESG due diligence, adapted to company size and sector. These assessments are disclosed in the relevant fund-level SFDR pre-contractual and website disclosures.

Sarsia Management AS reviews this approach regularly and may reconsider the assessment should data availability, regulation or investment strategy materially change.

Article 5 – Transparency of Remuneration Policies in Relation to the Integration of Sustainability Risks

Sarsia Management AS’ remuneration policy is designed to ensure sound and effective risk management and does not encourage excessive risk-taking with respect to sustainability risks.

Key principles:

• The remuneration structure supports long-term value creation consistent with the responsible investment approach.
• Integration of sustainability risks forms part of the investment team’s responsibilities and is reflected in performance assessments.
• Variable remuneration is not structured in a way that incentivises investment behaviour that could lead to inappropriate sustainability risk exposure.
• Governance, compliance, and risk-aligned behaviour – including ESG-related responsibilities – are part of individual evaluation.

This ensures that remuneration practices are consistent with the integration of sustainability risks into investment decisions and ongoing portfolio management.