Investor services are provided by Sector Capital AS, a wholly owned subsidiary of Sector Asset Management. We are 5 professional and dedicated employees based in Oslo, ready to help you out. Please see our contact information here.

Legal and regulatory information

Information to investors on MiFID categorisation and investor protection can be found here.

Sustainable Finance Disclosures

As of 27 April 2022

Introduction

In March 2021, the Sustainable Finance Disclosure Regulation (“SFDR”) came into effect. SFDR seeks to establish a pan-European framework to facilitate sustainable investment, by providing for a harmonised approach in respect of sustainability-related disclosures to investors within the European Union's financial services sector.

The scope of SFDR is extremely broad, covering a wide range of financial products and financial market participants. It seeks to achieve more transparency regarding how financial market participants integrate Sustainability Risks into their investment decisions and the consideration of adverse sustainability impacts into the investment process.

The objectives of SFDR are to

(i) strengthen protection for investors of financial products,

(ii) improve the disclosures made available to investors from financial market participants and

(iii) improve the disclosures made available to investors regarding the financial products, to amongst other things, enable investors make informed investment decisions.

Under Article 3 and 4 of the SFDR, information must be published on the integration of sustainability risks into investment decisions and/or investment advice, as well as on the consideration of the principal adverse impacts of investment decisions and/or investment advice on sustainability factors.

These SFDR-related disclosures apply for Sector Capital AS.

Integration of Sustainability Risks & ESG Factors

The SAM Group’s investment managers structurally integrate ESG factors into the investment decision-making process across all asset classes. The focus is on ESG factors that are material. It is up to the investment managers, analysts, and others involved in the investment research and decision-making process to determine what weight these factors should be given in each case.

Sector Capital AS integrates sustainability risks and ESG factors in our screening of the products we distribute. It is the intention of Sector Capital AS to meet growing investor demand for sustainable investments as well as investors’ increasing ESG-reporting requirements.

KYC and client onboarding

In line with regulatory and investor related requirements for sustainability assessment, Sector Capital AS has introduced sustainability preferences as a part of our KYC routine when onboarding new clients. Products that do not meet a customer’s sustainability preferences will not be recommended.

Product Governance and Product Review

Sector Capital AS is subject to regulations within MiFID II, which imposes a series of product governance rules on firms which manufacture and/or distribute financial instruments under MiFID II. The aim of the product governance rules is to ensure that manufacturers and distributors of investment products act in the client’s best interests during all stages of the life-cycle of products. The Board of Directors of Sector Capital AS is responsible for product governance, including the approval and ongoing oversight and evaluation of the products we distribute. This oversight and evaluation will specifically address sustainability risks in the evaluation of the products’ target markets.

Principal Adverse Sustainability Impacts

Sector Capital AS’ distribution business is relatively small (in terms of employees and products distributed). Further, Sector Capital AS’ distribution activities relates solely to products managed by the wider SAM Group. These managers currently do not consider the principal adverse impacts of their investment decisions on sustainability factors. Their reason for opting against doing so, is primarily that the that the regulatory technical standards (“RTS”) supplementing SFDR, which will set out the content, methodology and information required in the principal adverse sustainability impact (PASI) statement, remain in draft form and have been delayed. Therefore, Sector Capital AS has opted not to consider adverse impacts of investment decisions on sustainability factors in its investment advice. Sector Capital AS reserves the right to reconsider this position in the future, should e.g. more information and guidance be available, or should the managers of their product commence considering the principal adverse impacts of their investment decisions on sustainability factors.

Remuneration Policy

Sector Capital AS’ remuneration policy shall serve to promote sound management and control of Sector Capital AS and its clients’ risks, including sustainability risks, and shall not encourage excessive risk taking on the part of employees (in all aspects of its activities that relate to the services which are subject to public authorisation).

Key aspects of the Remuneration Policy are set out below:

(i) To which of Sector Capital AS’ employees and representatives this remuneration policy shall be applicable, in accordance with the abovementioned regulations concerning the calculation and payment of remuneration (Identified Employees). Such employees are divided into (a) executive management, (b) employees with control functions, (c) representatives and (d) employees whose responsibilities are of significant importance to Sector Capital AS’ or clients’ risk exposure. Regarding the last category in (d) above, employees with similar remuneration as executive managers and other employees with tasks of considerable importance to Sector Capital AS’ or clients’ risk exposure will be considered separately;

(ii) Whether the Company has more than 50 employees or total of assets under management that exceeds NOK 5 billion (and thus required to establish a remuneration committee); and

(iii) Which frameworks and guidelines that will apply to the calculation and payment of both the fixed and variable remuneration to those defined as “Identified Employees”.

The remuneration from the Company to Identified Employees may consist of a fixed and a variable element. The fixed element shall be determined on an individual basis and be sufficiently high (so that the Identified Employees of Sector Capital AS’ are not dependent on any relevant variable remuneration, enabling Sector Capital AS’ to not disburse the variable part of the remuneration).

Sector Capital AS has no guaranteed bonuses or sign-on fees.

We note that the Sector Capital AS’ sole Identified Employee is the CEO.

Sector Capital's Sustainability Policy can be found here.

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