Always Opportunities - Sustainability · Always Summer Asset Management

Environmental and/or social characteristics promoted

Always Opportunities promotes environmental and social characteristics by seeking to ensure that the companies and issuers in which it invests meet minimum standards of responsible business conduct and do not engage in activities that violate widely accepted international norms and conventions, and by excluding or restricting investments in certain activities that are assessed to cause significant adverse impacts on sustainable development.

The fund promotes the following characteristics:

Norms-based screening

The fund promotes adherence to international norms on human rights, labour rights, the environment and anti-corruption, as expressed in the UN
Global Compact Principles, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and the ILO Fundamental Conventions. Companies found to be in confirmed and ongoing violation of these norms are excluded from the fund's investable universe.

Activity-based exclusions and restrictions

The fund excludes or restricts investments in companies involved in: controversial weapons (including white phosphorus and depleted uranium), nuclear weapons (subject to geography and revenue thresholds), fossil fuels (thermal coal, unconventional oil and gas, and conventional oil and gas exploration and extraction, each at >5% revenue), tobacco production (>5% revenue), gambling (>5% revenue) and pornography production. The fund also excludes investments in government bonds from certain states and jurisdictions, and in sanctioned entities. Full details are set out in the fund's pre-contractual disclosure (Annex II).

No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by the fund.

Investment strategy

Always Opportunities is an actively managed alternative investment fund primarily investing in Nordic credit instruments, including high yield bonds, convertible bonds, hybrid instruments, traded loans and credit derivatives. The fund may also invest in equities and equity-linked instruments. The fund targets a diversified portfolio of 40–50 holdings with a Nordic focus while retaining the flexibility to capture opportunities globally.

The binding elements of the strategy used to attain the promoted E/S characteristics are:

Pre-investment norms-based screening of all eligible holdings using data from a recognised third-party ESG data provider.
Pre-investment exclusion and restriction screening against the fund's activity-based criteria.
Ongoing monitoring of the portfolio, with a defined process for review and divestment in the event a holding is found to be in violation of the screening or exclusion criteria.

Good governance

The fund assesses the good governance of investee companies with regard to sound management structures, employee relations, remuneration of staff and tax compliance. This assessment is carried out through the norms-based screening (which captures governance failures), the investment analysis process (which includes review of third-party governance risk flags, management quality, board oversight and financial transparency) and ongoing monitoring of governance incidents and regulatory actions.

Asset allocation

A minimum of 60% of the fund's net asset value is invested in holdings that are aligned with the promoted environmental and/or social characteristics, meaning they have been screened and are not in violation of the norms-based or exclusion/restriction criteria.
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A maximum of 40% of the fund's net asset value may be held in investments classified as "Other", including cash, cash equivalents, derivative instruments used for hedging or efficient portfolio management, newly acquired positions pending screening, and positions in the process of divestment.
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The fund does not commit to a minimum proportion of sustainable investments or EU Taxonomy-aligned investments.

Monitoring of characteristics

The attainment of the promoted characteristics is monitored using the following sustainability indicators:

The percentage of the portfolio screened against international norms (target: 100% of eligible holdings).
The number and value of holdings identified as being in confirmed norms violation (target: zero in the portfolio).
The number of holdings in breach of the exclusion or restriction criteria (target: zero).
Engagement activity initiated in response to watchlist holdings, where applicable.

Monitoring is performed on an ongoing basis. The results are included in the fund's annual report.

Data sources and methodologies

The fund's norms-based screening, exclusion screening and activity classification are carried out using data from a recognised third-party ESG data provider. The data provider applies a research-based methodology to identify companies in violation of international norms and to classify company involvement in excluded or restricted activities based on revenue thresholds, geographic criteria and direct involvement criteria.
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The fund manager supplements the third-party data with its own assessment and, where necessary, direct engagement with issuers.

Limitations to methodologies and data

The following limitations apply to the data and methodologies used:

Coverage

Third-party ESG data coverage may be limited for unlisted companies,
privately placed instruments and smaller issuers. Where data is not available from the third-party provider, the fund manager conducts its own assessment based on publicly available information and direct dialogue with the issuer.

Timeliness

There may be a time lag between the occurrence of a norms violation or a change in a company's activity profile and its identification by the data provider.

Subjectivity

Norms-based assessments inherently involve a degree of judgement in
determining whether a violation has occurred and whether it is confirmed and ongoing.

Derivatives

Certain derivative instruments, particularly index-based or basket-based
instruments, may not allow for individual screening of all underlying exposures.

These limitations are mitigated by the fund manager's own assessment, ongoing portfolio monitoring and, where applicable, direct engagement with issuers. The limitations are not expected to materially affect the fund's ability to attain the promoted environmental and social characteristics.

Important information

Sustainability

Risk information

Environmental and/or social characteristics