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1.   Summary

This document provides detailed sustainability-related disclosures regarding SKAGEN's equity products that are categorised as Article 8 as provided in Article 32 of the Sustainable Finance Disclosure Regulation Level II proposal text from the European Supervisory Authorities.

SKAGEN's equity funds execute an ESG Integration Strategy throughout the investment lifecycle. The ESG Integration Strategy is intended to enhance the overall investment objective of each product mandate; namely to provide the best possible risk-adjusted returns to unit holders. While the equity funds each have their own particular mandate and investment strategy, the same four ESG pillars apply to each of the investment cases they identify. These four pillars consist of:

  1. Exclusion of investments in a range of non-sustainable products, businesses and activities
  2. Enhanced due diligence for companies in high-emitting industries
  3. ESG integration through dedicated factsheets for each investment
  4. Active ownership

The Sustainable Investment Policy, embedded at Board level, binds all SKAGEN products to its principles, which in turn builds on broader Storebrand Group level policies. The ESG Integration Framework puts these binding guidelines into practice, meaning that our equity funds promote environmental and social characteristics, but do not have sustainable investment as their objective.

SKAGEN's equity funds manage environmental and social factors by applying binding elements throughout the investment process. Exclusion and negative screening of a range of non-sustainable products, businesses and activities are the first steps deployed to assess environmental and social characteristics of an investment. Second, when constructing an investment thesis, environmental, social and governance characteristics are collected, measured, and assessed - coupled with enhanced due diligence of climate risk of companies in high-emitting sectors. Third, assessment of these factors is tied to the investment thesis of each investment – driven by a traffic light model to indicate the estimated degree of ESG risks and opportunities. The product assesses the double materiality of environmental and social characteristics that are of relevance at investment level. Lastly, active ownership through dialogue, engagement and voting is a lever that is deployed by the product to work for factor improvement over time. Double materiality considerations are continuously assessed. If salient sustainability risks (harm to investment) or principle adverse impacts (potential harm by investing) are not improving, the holding in an investee company will ultimately have to be divested should the investee company fail to mitigate these. Quarterly checks and controls are conducted of the holdings in the product to monitor developments of events and general exposure, to ensure alignment with the Sustainable Investment Policy of the entity and broader Storebrand Group.

2.   No sustainable investment objective

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

3.   Environmental or social characteristics of the financial product

SKAGEN's equity funds promote environmental and social characteristics because they deploy an ESG Integration Strategy throughout the investment process. The ESG integration strategy consists of four pillars to execute the investment selection process and exercise ownership rights. The first pillar of the strategy is negative screening and control of potential investments, the second is an enhanced due diligence of companies in high emitting sectors*, the third is ESG integration through dedicated factsheets, whilst the fourth and final pillar is active ownership.

* Energy equipment & services, oil, gas & consumable fuels, chemicals, construction materials, containers & packaging, metals & mining, paper & forest products, transportation, automobiles, food products, utilities, real estate segments focusing on data centres and industrial real-estate.

4.   Investment Strategy

Each equity fund has a dedicated investment strategy and mandate. What unites these respective investment strategies, is that the sole objective of the funds is to generate the best possible risk-adjusted returns, with the ESG integration strategy being a key component in meeting this objective. Given their active and broad investment mandates, the funds do not make an ex-ante commitment to invest in a specific sector, geography or theme - including sustainable or taxonomy-aligned investments as an end or objective in and of itself. Please consult the Key Investor Information Documents for more information about the product-specific investment strategies.

5.   Proportion of Investments

All products in SKAGEN, including our equity funds, adhere to the group-wide exclusion criteria. Moreover, the equity funds add additional layers of ESG integration in the investment process for each specific investment case. As our equity funds are actively managed, they do not have a planned asset allocation for investments. In principle, all the assets under management should be aligned with environmental or social characteristics. De-facto, this number is slightly lower with the remainder being categorised as 'Other' due to AuM set aside for cash position of the product, potential derivatives and other money market instruments needed to manage the funds.

6.   Monitoring of environmental or social characteristics

Investment Process:

SKAGEN's equity funds manage environmental and social factors by applying binding elements throughout the investment process. Exclusions and negative screening are the first steps deployed to assess the environmental and social characteristics of an investment. Second, when constructing an investment thesis, environmental, social and governance characteristics are collected, measured, and assessed - coupled with enhanced due diligence of climate risk of companies in high-emitting sectors. Third, assessment of these factors is tied to the investment thesis of each investment – driven by a traffic light model to indicate estimated degree of ESG risks and opportunities. The product assesses the double materiality of environmental and social characteristics that are of relevance at investment level. Lastly, active ownership with holdings is a lever that is deployed by the product to work for factor improvement over time. Double materiality considerations are continuously assessed. If salient sustainability risks (harm to investment) or principle adverse impacts (potential harm by investing) are not improving, the holding in an investee company will ultimately have to be divested should the investee company fail to mitigate these. Quarterly checks and controls are conducted of the holdings in the product to monitor developments of events and general exposure, to ensure alignment with the sustainable investment policy of the entity and broader Storebrand Group.

Prior to investing, the portfolio manager is required to forward potential investment cases to the ESG team who conduct a screening and approval of the potential investment at hand. This screening process assesses whether the investment case aligns with the entity level investment policy or is in violation of it. If it is in violation of the norms-based and product-based exclusion criteria, the company may not be invested in and will be rejected during the screening phase. Moreover, the product is subject to quarterly screening controls to ensure continued compliance with global norms and our exclusion criteria.

Second, the portfolio manager is required to draw up a dedicated ESG factsheet for the investment case, identifying material ESG information and defining an engagement plan for managing ESG associated risks – or undervalued opportunities – through active ownership. Here, contextual and relevant ESG factors are tied to the investment thesis. The degree of ESG risk of each investment is assessed using a traffic light model, where short-term results and degree of engagement increase in step change with the level of risk. To avoid conflicts of interest, it is the task of the ESG team to determine the traffic light assessment of an investment case. In response to this, the portfolio manager, in collaboration with the ESG team, must articulate a clear plan on environmental and social risk mitigation.  The portfolio manager must also state financial considerations that have been made on the back of the ESG profile of the investment at hand. ESG risks that fail to be mitigated following escalation strategies will be excluded as this will be deemed a thesis violation.

Monitoring at fund and entity level:

There are formalised processes in place for monitoring environmental and social characteristics at fund and entity level, in addition to investment process-related monitoring of environmental and social characteristics.

Fund level:

Every quarter, each fund is subject to a quarterly control in order to ensure continued alignment with our Sustainable Investment Policy. This control is carried out by the ESG Team and is communicated transparently to key stakeholders internally. The quarterly controls also serve as a helpful format for identifying new developments and determining potential support for the fund in question.

Entity level:

SKAGEN's Sustainable Investment Policy is frequently reviewed by our Board of Directors, which provides strategic feedback on the content and positioning of the Sustainable Investment Policy. Moreover, as the Board authorises each equity fund to exercise its ownership rights on behalf of unit holders, they receive frequent updates on our engagement activity. Entity and board level oversight ensures wider transparency and accountability around the execution and management of environmental and social factors.

7.   Methodologies

The following methodologies are deployed under the respective pillars that inform the environmental and social characteristics of the equity products:

1.     Exclusion:

As defined by SKAGEN's exclusion criteria, we do not invest in a company if it falls in under one of two themes. The first is product specific – exclusion of companies that are exposed, via a certain share of revenue, to certain products. The other exclusion criteria exclude companies that violate global norms such as the UN Global Compact and the OECD Guidelines for Multinational Enterprises. Whenever a new investment case is identified, the portfolio manager in question must forward a screening request to the ESG Team which will assess whether the investment is in breach of our exclusion criteria. To assess this, we rely on a third-party ESG data provider.

If the third-party provider indicates that the investment has controversial business involvement, we will assess further if the controversial business involvement includes one of the products which we exclude. If it does, and it exceeds the allotted income threshold, the investment request is rejected. If the revenue exposure does not exceed the allotted income threshold, the portfolio manager receives a caution about the exposure and is informed that the share of revenue might exceed the threshold during the investment period, which would result in divestment of the holding. The guiding principle behind this exclusion theme is to avoid investing in activities that are instrumental for that activity.

For the second exclusion criteria, we look at potential flagging that the third-party provider has identified that could indicate potential breach of our norms-based exclusion criteria. We prioritise such controversies according to the degree of severity, how recent the controversy is and its estimated impact on violating the UN Global Compact and OECD Guidelines for Multinational Corporations. Whilst a controversy might not be serious enough to warrant an exclusion, a recommendation may be made to engage with the company in question in order to assess the controversy and seek to remedy it, if the company is invested in.

Ultimately, the information provided by the third-party data provider is not considered an objective truth, but is used as the basis for making our own informed decision.

2.     Enhanced due diligence of companies in high emitting sectors

The following industries are subject to an enhanced due diligence: energy (electricity & heat, industry, transportation) and agriculture. Real estate companies in the data storage segment and industrial real estate segment are also considered as high-emitting industries. Subject to data availability, the following sustainability indicators are used to measure the attainment of the environmental or social characteristics promoted by this financial product:

  • GHG emissions
  • Carbon footprint
  • GHG intensity of investee companies
  • Exposure to companies active in the fossil fuel sector
  • Share of non-renewable energy consumption and production
  • Energy consumption intensity per high impact climate sector  
  • Activities negatively affecting biodiversity sensitive areas
  • Share of investments in investee companies that have been involved in violations of the UNGC principles or OECD Guidelines for Multinational Enterprises

Parameters to be assessed in the enhanced due diligence assessment:

The purpose of conducting an enhanced due diligence assessment is to uncover and document climate-related risks and assess relative impact on double materiality. The following aspects must be assessed:

  • Principle Adverse Impact emission indicators and their delta
  • Transition Pathway
    • Minimum expectation that companies that fall in scope have articulated a clear transition pathway.
    • A fund might invest in a company that does not have a transition pathway on the condition that it is deemed reasonable that the company will articulate one in the near future either of its own volition or through pressure by active ownership from investors.
  • The company will be subject to annual reviews to assess progress. If a company fails to signal effort and commitment, this should be deemed a thesis violation.
  • Assessment of reputational risk and financial risk; with a corresponding engagement plan

3.     ESG Factsheet

ESG Factsheets are gradually being implemented for equity investment cases. These ESG factsheets serve to document and navigate company-specific ESG factors including risks, opportunities, and a potential engagement plan. Traffic light indicators serve as a key feature informing the nature of each ESG factsheet. The colour of the traffic light is determined by the ESG team on the basis of material ESG data that is populated as the basis for each factsheet. These data include company-specific and material ESG factors, controversies, UN Global Compact status amongst other things.  These data form a sum-of-the-parts consideration determining the traffic light assigned to the company. Portfolio managers, in turn, assess the traffic light and underlying ESG data and further populate the factsheet with qualitative information on how the ESG profile has impacted investment decisions as well as formulating potential engagement plans and KPIs.

4.     Active Ownership

The ESG factsheets serve as a helpful reference when executing an investment case and can inform proactive and reactive active ownership processes with investee companies.


There is no methodology per se for exercising our voting rights. SKAGEN makes use of a third-party proxy provider to facilitate our voting activity. An overview of our voting activities is publicly available on our website.


SKAGEN has developed a proprietary tool to register, log and monitor engagement dialogues with companies. This tool also provides an interface that generates descriptive figures for reporting purposes on various engagement metrics. SKAGEN defines engagements as interactions that make up a dialogue – a single request or communication post does not constitute an engagement. We report on our engagement activity according to several different parameters in our quarterly and annual ESG reports, in addition to providing case studies.                        

For further information on Engagement, please see Section 11. Engagement Policies.           

8.   Data sources and processing

SKAGEN sources ESG data from a handful of third-party data vendors. As a bottom-up and active investor, SKAGEN is reluctant to accept any data at face value, and we prefer access to structured, but raw company-reported ESG data. We do not make use of numerical ESG scores in the investment process beyond ascertaining endogenous relative rank vis-à-vis peers. Some data vendors are applied consistently – such as in the screening process, as they have extensive data and information on aspects that can potentially violate our exclusion criteria (controversy data, product involvement data and potential breaches with the Global Compact and OECD Guidelines for Multinational Enterprises). Other data vendors are used for more specialist cases, or as a basis for computing quantitative ESG data in enhanced due diligence processes and ESG factsheets. All data is collected and processed manually and maintained in dedicated databases for analysis and reporting purposes.

9.   Limitations to methodologies and data

There are clear limitations to the methodologies referred to in section seven as well as to the data sources and data processing referred to in the previous section. The first limitation is lack of data availability. There are also significant biases in ESG data, where quantity is conflated with quality data as well as data consistency issues. Time inconsistency of data and increasing expansion of data coverage can result in data-lag with new information manifesting in quarterly controls that was not known when screening the company, which can also influence investment decisions. These data consistency issues pertain to ESG data values for one variable for one specific time period varying from source to source, which reduces the face validity of such data as well as best guess estimates that might be used as proxies for missing data.

However, such limitations do not affect the attainment of environmental or social characteristics promoted by the equity products as such. As the attainment of said characteristics are defined by process and how this process is systematically and routinely integrated into the investment process rather than promulgating a data-driven outcome claim on behalf of the investment strategy. Yet, these limitations do dilute the efficacy of company-specific ESG analysis and ESG integration for the products. SKAGEN seeks to address such limitations by prioritising data coverage on the most salient and material ESG factors – which will vary from sector to sector. Specific actions to address these limitations therefore focus on cross-referencing data across different sources to ensure a certain level of data consensus, engaging and requesting data directly from investment companies or using appropriate estimates where relevant.

10. Due diligence

The ESG Investment Strategy, informed by the Sustainable Investment Policy, is the key process to conduct initial due diligence of investments in the equity funds. Moreover, there are broader and formalised structures in force to ensure continued due diligence and control. The equity funds are subject to quarterly screening and control, conducted by the ESG Team. Ensuing screening reports are produced and provided to portfolio managers, select leaders and compliance. Moreover, the Sustainable Investment Policy is anchored with the Board of Directors, which is also responsible for giving the portfolio team Power of Attorney to execute ownership rights on behalf of unit holders. The Board of Directors receives frequent updates on the execution of ownership and offers guidance on the Sustainable Investment Policy. In sum, the ESG Integration Strategy, the Sustainable Investment Policy and broader controls and due diligence processes help ensure that due diligence of investment activities is an ongoing process.

11. Engagement policies

As stated in our Sustainable Investment Policy, which aligns with responsible business codes and internationally recognised standards, SKAGEN believes in exercising our rights as shareholders. We employ two main ways of doing this. Either through voting at shareholder meetings or engaging – through direct dialogue – with the management and board members of our various holdings.

Both tools can be very effective in addressing concerns regarding environmental, social and corporate governance matters. Combined they can strengthen one another and be an effective signal to companies on where we stand on various important issues. We will therefore use both methods to influence companies’ behaviour over time.

The decision to engage with select companies is made based on our assessment of the significance of a particular matter, the size of the holding, the scope to effect change and the opportunity to collaborate with other investors. Dialogue with companies can be exercised by expressing views, in writing or orally, to the company's management on all levels, advisers, and Board of Directors.

Active ownership is a key pillar for our equity products. We do not exercise active ownership for our fixed income products as they do not have voting rights nor do the products engage with their constituent holdings. Whilst our fund-of-funds' products do not have voting rights, they nonetheless engage with external products on ESG topics.

Cases for engagement

 We will consider engaging with companies in the following cases:

  • Serious or systematic breaches of human rights
  • Corruption and bribery
  • Serious environmental and climate damage
  • Companies with a low sustainability rating in high-risk industries
  • If the company's strategy or results differ substantially from those previously communicated
  • Governance issues such as:
    • Replacement of directors
    • Equity issues and dividend policies
    • Remuneration of key personnel
    • Transactions between related parties
    • Diversity issues

In addition, we will seek to engage with companies on climate change. For some of our funds – and given the nature of the investment style - the carbon footprint may vary substantially over time. Still, we are committed to working with our holdings to reduce their carbon footprint and operate more efficiently over time. Climate change is one aspect considered when monitoring companies and those companies lagging in their efforts to reduce their carbon footprint may be subject to engagement. We will engage with and encourage those companies that are in a position to reduce their carbon footprint.

Engagement alternatives

If the outcome of the company engagement does not meet our expectations, we may consider other actions. If a company is on the observation list, we will make an exclusion assessment. For other companies, our actions may include:

  • Expressing our views publicly
  • Proposing resolutions at the annual general meeting
  • Suggesting an extraordinary general meeting

We may engage with companies in collaboration with other investors where we believe this to be in the interests of the unit holders.

When working with other investors to influence companies, we will be acutely aware of potential conflicts of interest and of being put in an insider position.


The framework for the use of voting rights for funds managed by SKAGEN is set out in the Norwegian Regulations on Securities Funds Section 2-24 and in the industry recommendations from the Norwegian Fund and Asset Management Association.

The ultimate responsibility for execution of corporate governance in SKAGEN lies with the Board of Directors. The daily execution is delegated to the portfolio managers of each fund and activities are reported back to the Board. The Board annually evaluates the execution of corporate governance.

Guidelines for Voting

Voting rights must be exercised to the benefit of the fund in question, with the objective of securing the best possible risk-adjusted returns for unit holders. Generally speaking, the portfolio manager assesses how the voting rights are to be used. In all cases where we vote, the respective portfolio manager familiarises him or herself with the matters to be discussed at the general meeting and decides how to vote. Voting rights are exercised directly by the fund management company or by using a proxy voting platform. For details see the Voting Policy (link).

SKAGEN typically votes against management in the following situations:

  • Inadequate information ahead of meeting
  • Quality of board and its members
  • Anti-takeover mechanisms
  • Needless or unfair changes in capital structure
  • Excessive executive compensation
  • Disclosure proposals related to climate change

Specific situations may call for a unique response and we will always take market and company conditions into consideration. To the extent that voting rights have been exercised in controversial cases or where we have voted against the board’s or management’s recommended course of action, we will disclose the voting rationale.

Voting Process

We have selected Institutional Shareholder Services (“ISS”), an independent service provider, as the platform for our proxy voting activities. ISS provides notices of general meetings and comprehensive information about the companies, the voting items on the agenda and recommendations. Funds managed by SKAGEN will vote according to our own voting policy, and always in what we deem to be the best interests of our unit holders. When we do not have a policy in place for a specific ballot item, we will typically follow the ISS recommendation. We will review the relationship with ISS on an annual basis, including the quality and effectiveness of the services provided. Each fund has a custodian approved by the Financial Supervisory Authority of Norway. The custodian bank also provides information related to general meetings. Our voting record is publicly available on our website and is disclosed in quarterly and annual sustainability reports.


Important notice: This text is correct at the time of writing, but may be amended subject to the publication of more detailed Level 2 rules and disclosure requirements of SFDR on 1 July 2022

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