Sustainability | Nordnet Bank AB




Nordnet Fonder is a wholly owned subsidiary of Nordnet Bank. The fund company started operations in May 2022 and offers funds in all markets where Nordnet operates - Sweden, Norway, Denmark and Finland. The goal of the business is to conduct qualitative and cost-effective management focused on broad asset classes for long-term savers. Sustainability is an important component of our management work, and the prospectus for each fund contains more information on how our various funds take sustainability into account in their management. You can read more about the Nordnet Group's overall sustainability work here.

No consideration of Principal Adverse Impacts

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Nordnet Fonder does not consider PAI (Principal Adverse Impacts). The reason is that Nordnet Fonder only manages fund-of-funds and equity index funds. When investing in securities funds, Nordnet Fonder cannot directly influence which companies they invest in. The investment decisions in Nordnet Fonder's equity index funds are governed by the companies included in the indices that the funds' investments are to emulate

Integration of sustainability risks in the investment decision process

Version 1.0, Updated 2022-11-09

The following describes how Nordnet Fonder AB ("Nordnet Fonder") integrates sustainability risks in its investment decision process. The EU's Sustainable Finance Disclosure Regulation (SFDR) defines sustainability risk as an environmental, social or governance-related event or circumstance that, if it occurs, could have a significant negative impact on the value of the investment.

How sustainability risks are integrated

Nordnet Fonder considers sustainability risks in investment decisions for all funds except Nordnet Indeksfond Norge. There are several different methods of working with sustainability risks - for example through influencing companies, inclusion of companies or sectors, exclusion of companies or sectors, or through a combination of several different ways. Nordnet Fonder has chosen to work with exclusion, which means that before a potential investment, Nordnet analyzes the instrument that the investment is intended for to ensure that they are not invested in any company that is to be excluded according to the fund rules.

All funds

Nordnet Fonder manages twelve fund-of-funds and four equity index funds. The fund-of-funds are invested in other mutual funds managed by Nordnet Fonder as well as external fund companies. The equity index funds are invested according to the underlying index specified in the respective fund's fund rules.

Nordnet Fonder considers sustainability risks in all funds' investments, except regarding Nordnet Indeksfond Norge. Nordnet Fonder does not invest in companies, either directly or indirectly through underlying fund investments, that systematically violate international standards based on the UN Global Compact's ten principles of human rights, labor law, the environment and corruption.

Nordnet Fonder also does not invest in companies, either directly or indirectly through underlying fund investments, involved in controversial weapons such as cluster bombs, landmines, chemical and biological weapons.

Nordnet Fonder follows up on funds' underlying assets to ensure that these are in line with the sustainability criteria set for each fund.

Regarding fund-of-funds

At least 60 percent of the investments must consist of mutual funds that either promote environmental or social properties, alternatively have sustainable investments as a goal. They must therefore be classified as either Article 8 or 9 according to SFDR. Of the remaining 40 percent, a maximum of 20 percentage points of the investments may be made in equity funds that neither promote environmental or social characteristics nor have sustainable investments as their goal.

Nordnet Fonder strives in every investment decision to primarily invest in funds classified as Article 8 or 9.

Regarding equity index funds Nordnet Indexfond Sverige ESG, Nordnet Indeksirahasto Suomi ESG and Nordnet Indeksfond Danmark ESG

The investments must only include shares that meet special sustainability criteria (exclusion criteria) and that are included in the indices OMX Stockholm Benchmark ESG Responsible Index, OMX Helsinki 25 ESG Responsible Index and OMX Copenhagen 25 ESG Responsible Index respectively. The exclusion criteria are those established by the index provider Nasdaq.

Regarding Nordnet Indeksfond Norge

The investments must only include shares included in the OBX Index, which is provided by Euronext.

Sustainability-related due diligence

The fund-of-fund invest in other mutual funds managed by Nordnet Fonder or external fund companies. All external fund companies undergo a due diligence process carried out by Nordnet Fonder before investment and thereafter at least annually, in which the fund companies' sustainability work and the product's sustainability orientation are evaluated.

The equity index funds invest in listed securities, exchange-traded funds and derivative instruments. All equity index funds' holdings are checked on an ongoing basis in order to ensure that each equity index fund only invests in permitted financial instruments according to the underlying index.

In cases where Nordnet Fonder is provided with services in its fund management, Nordnet Fonder must follow up that the supplier considers sustainability risks, where it is deemed relevant. For example, the index suppliers are monitored at least once a year.


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Remuneration policy

Version 1.0, Updated 2022-11-09

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Nordnet applies a compensation strategy that aims to stimulate employees to deliver sustainable results that are compatible with Nordnet's strategy, the interests of shareholders and customers, as well as with sound and efficient risk management.

Nordnet offers competitive compensation that is based on business needs and that is determined regardless of gender, transgender identity or expression, sexual orientation, ethnicity, belief, disability or age. The compensation system in Nordnet aims to attract, motivate and retain personnel with the ability, experience and skills to deliver on Nordnet's strategy in accordance with Nordnet's values.

The basic principle is that Nordnet employees have fixed remuneration, which is based on the nature and responsibility of the employee's position, the individual results and market conditions. Pension benefits are offered in accordance with collective agreements, rules and practices in the country where the employee is permanently resident. Variable remuneration occurs to a very limited extent. The variable remuneration is of a one-off nature and is used, for example, to reward employees who, in accordance with Nordnet's goals and values, have delivered above expectations in the final stage of a critical project. Non-compliance with external or internal rules and regulations or deficiencies in risk management are circumstances that will be considered incompatible with Nordnet's values.

Sound risk-taking is part of Nordnet's business strategy and the compensation system is designed to discourage excessive risk-taking and encourage employees to deliver sustainable results that are consistent with the strategic goals. Nordnet integrates ethical, social, environmental and financial considerations into its business decisions and our remuneration system is deemed to be compatible with these considerations.


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1.0 First version of document 2022-11-09

Shareholder engagement

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As a fund company and AIF manager, the Company shall represent shareholders in all matters relating to the Company's funds, including ownership issues.

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