Instructions for risk managemen

These instructions summarize Slättö Förvaltning AB and funds managed by Slättö Förvaltning AB’s instructions, routines and processes in relation to risk management, liquidity management, financial leverage, operational risk and sustainability risks. Risk management enables the Company to effectively manage uncertainty and related risks and opportunities. Slättö Förvaltning AB’s Board of Directors has adopted the “three lines of defence” principle based on AIF management and functions that own and manage risks, risk and regulatory compliance function and internal audit functions.

Investment Committee policy

The Board of Slättö Förvaltning AB has appointed an Investment Committee to make portfolio management decisions on behalf of the funds. In addition, the Board has adopted this policy, which is intended to describe the composition of the Investment Committee and the regulations and frameworks that guide the Investment Committee’s work. The policy also describes the routines that exist regarding various steps in decision-making and the execution of portfolio management decisions.

Portfolio management decisions must be made on a sound basis including market analysis, SWOT, a review of sustainability risks and results of due diligence. Investments must align with the Company’s investment strategy and fund agreements. The policy also includes instructions on how to address conflicts of interest.

Instructions regarding measures to prevent money laundering and terrorist financing

These instructions are based, inter alia, on Swedish acts and regulations regarding money laundering and terrorist financing. They are designed to ensure that the Company has well-functioning and effective routines to prevent the business from being used for money laundering and terrorist financing at all times. The Company is required to enforce instructions and implement routines to prevent money laundering and terrorist financing due to the Company’s activities.

Instructions for the management of conflicts of interest

Conflicts of interest may arise as a natural part of many business-driven activities. As an AIF manager, all reasonable steps must be taken to avoid conflicts of interest. This instruction is intended to establish routines to ensure that the Company meets requirements for identifying, managing and reporting conflicts of interest that may arise in its business activities.

Conflicts of interest that arise in connection with the remuneration of employees within the Company are documented and managed within the AIF manager’s remuneration policy.

Compliance instructions

These instructions clarify the Board’s responsibility for introducing, applying and maintaining appropriate guidelines and procedures for detecting risks associated with the Company failing to fulfil its obligations under laws and regulations. The Company’s board is ultimately responsible for ensuring that the Company’s operations are conducted in accordance with applicable rules, including laws and ordinances as well as government regulations, general advice, internal policies, instructions and similar industry and market practices.

The Company’s CEO is responsible for day-to-day operations and that the internal rules established by the Company are implemented and applied in daily operations. Management is supported in this by a Compliance Officer, appointed by the Board, who works independently of the Company’s business operations in accordance with these instructions.

Remuneration policy

The Company’s remuneration policy is partly compatible with and promotes sound and efficient risk management, and partly counteracts risk-taking that is incompatible with alternative investment funds’ risk profile, fund regulations, articles of association or equivalent regulations. The Company also follows the guidelines for sound remuneration policy published by the European Securities and Markets Authority (ESMA) and other employment laws and regulations that apply in Sweden.

The Company shall analyse which risks, including sustainability risks, are associated with AIF Management (AIFM) remuneration policies and remuneration practice. The Company must, on the basis of the analysis, identify specially regulated staff at the AIFM.

Code of Conduct

Slättös Code of Conduct sets out how we work and guides us in our business relationships. It is based on the UN Global Compact’s 10 principles on human rights, labour law, the environment and anti-corruption. The Code of Conduct applies to all the Company employees and consultants.

Supplier Code of Conduct

The Company’s suppliers are an important part of our performance and impact in the area of sustainability. Our Supplier Code of Conduct aims to clarify requirements and guidelines for the Company’s suppliers and covers all the Company's suppliers, including subcontractors and partners. The Code is based on the 10 principles of the UN Global Compact. Serious breaches of the Code are always considered a material breach of contract.

Our Supplier Code of Conduct is supplemented with a due diligence Q&A for the Company’s contracted suppliers.

Sustainability Policy

Slättös Sustainability Policy clarifies guidelines for how the Company’s sustainability work is to be conducted. It applies to all employees and all parts of the Company’s operations. Sustainability activities must be conducted on a daily basis and contribute to the sustainable development of the Company as well as of society.