Nordic Venture Secondary Fund
Nordic Venture’s Missing Piece
Providing liquidity to the Nordic venture market.
This page sets out the entity-level sustainability-related disclosures of Aurora Capital Management AS (the “Manager”) under the Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088, “SFDR”), as applied in Norway.
SFDR Article 3 requires fund managers such as the Manager to publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process. Sustainability risks are defined in the SFDR as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment.
The Manager includes sustainability risks in its ordinary assessment of risks associated with a potential investment. This means that the Manager typically seeks to identify sustainability risks through its due diligence process prior to any fund investment or direct investment and takes sustainability risks into account as part of the overall risk assessment. The Manager does as a starting point not emphasise sustainability risks more than other risks, and will typically — due to its investments being in other funds or minority stakes in companies — not take any measures to mitigate identified sustainability risk associated with an investment. Sustainability risk may however — as any other financial risk — be a determinative factor for avoiding investments, either as a standalone factor or taken together with other risks.
Review. This policy is kept under review and updated as the Manager’s activities, portfolio and the availability of sustainability data evolve.
SFDR Article 4 requires fund managers such as the Manager to publish and maintain on their websites information on whether they consider principal adverse impacts (PAI) of investment decisions on sustainability factors and, if they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons therefor, including, where relevant, information as to whether and when they intend to do so. Sustainability factors are environmental, social and employee matters, respect for human rights, anticorruption and anti-bribery matters, and PAI are the most significant negative impacts of investment decisions on these factors.
The Manager does not currently consider the adverse impacts of its investment decisions on sustainability factors.
Explanation. Given the nature, scale and stage of the investments of the funds under the Manager’s management — i.e., secondary acquisitions of existing fund and company positions, typically as minority holdings — the data required for reporting on the standardised PAI indicators is commonly unavailable, incomplete or non-verifiable, and the Manager considers that PAI reporting would not at this stage be proportionate. The Manager keeps this position under review and will reconsider it as its size, portfolio and access to data develop.
SFDR Article 5 requires fund managers such as the Manager to publish on their website information on how their remuneration policies are consistent with the integration of sustainability risks.
Employees of the Manager receive a fixed salary aligned with role, responsibilities, and market benchmarks. There is no variable remuneration. The Manager also provides statutory/contractual pension contributions and standard employee benefits.
The remuneration structure promotes sound and effective risk management and does not encourage risk-taking that is inconsistent with the risk profiles of the funds managed, including with respect to sustainability risks. The structure reflects the Manager’s size, internal organisation and the nature, scope and complexity of its activities.
Version 1 — 27 August 2026.