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Sustainability related disclosures

Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”) for Baltic Horizon Fund (the “Fund”).

Northern Horizon Capital AS (the “AIFM”) identifies and analyses sustainability risks as part of its risk management process. The AIFM also integrates sustainability risks in the investment decision-making process. As part of the due diligences performed prior to each target investment, an analysis is made of the sustainability risks of such investments in light of information and data collected before taking an investment decision. The scope of such information and data may vary on a case-by-case basis depending on the profile of the target investment.

The AIFM believes that the integration of this risk analysis could help to enhance long-term risk adjusted returns for investors, in accordance with the investment objectives of the Fund. Sustainability risk means an environmental, social, or governance event or condition that, if it occurs, could potentially or actually cause a material negative impact on the value of a Fund’s investment. Sustainability risks can either represent a risk of their own or have an impact on other risks and may contribute significantly to risks, such as market risks, operational risks, liquidity risks or counterparty risks. Sustainability risks may have an impact on long-term risk adjusted returns for investors. Assessment of sustainability risks is complex and may be based on environmental, social, or governance data, which is difficult to obtain and incomplete, estimated, out of date or otherwise materially inaccurate. Even when identified, there can be no guarantee that these data will be correctly assessed.

Consequent impacts to the occurrence of sustainability risk can be many and varied according to a specific risk, region or asset class. Generally, when sustainability risk occurs for an asset, there will be a negative impact and potentially a total loss of its value and therefore an impact on the net asset value of the concerned Fund.

For the time being, except as may be otherwise disclosed at a later stage on its website, the AIFM does not consider adverse impacts of investment decisions on sustainability factors. The main reason is actually the lack of information and data available to adequately assess such principal adverse impacts.

The Fund takes sustainability risk and environmental, social and governance (“ESG”) characteristics into account as part of its selection process. In that respect, the Fund promotes, among other characteristics, environmental and/or social characteristics within the meaning of Article 8 of SFDR. We believe that the Fund’s asset management strategy in particular promotes environmental characteristics. The asset management strategy emphasizes sustainability by tracking consumption metrics and improving environmental performance of Fund’s assets in the long-term.

The investment universe is determined by the AIFM by using property level information and third-party data.

The due diligence performed in relation to each target investment not only focuses on the current sustainability status and criteria of the target at the time of acquisition, but also includes an analysis on the perspectives of development of the underlying investment in this regard.