Investtech’s Sustainability Strategy

1. BACKGROUND
The EU has introduced sustainability regulations for the financial sector to direct capital flows toward more sustainable investments and support the EU’s goal of climate neutrality by 2050.
This has been done through the taxonomy for sustainable activities, the SFDR (Sustainable Finance Disclosure Regulation), and the CSRD (Corporate Sustainability Reporting Directive). MiFID II has also introduced rules regarding sustainability considerations and assessment requirements. The main objective of MiFID II is to increase transparency, strengthen investor protection, and improve stability in financial markets.

In February 2025, the European Commission proposed changes to sustainability reporting requirements, which would reduce the number of companies required to report and delay and simplify reporting obligations.
EU priorities directly impact Norwegian businesses, including Investtech.com AS.

2. PURPOSE
Investtech.com AS was founded in 1997 and is a leading Norwegian company in behavioral finance research and technical stock analysis. Investtech’s research findings are applied in a decision-support system that analyzes stocks and other securities. Advanced mathematical models and statistical optimization form the basis of the analyses, providing objective and transparent decision support. Investtech provides web-based subscription services for private investors and has been a prominent provider of technical stock analysis to financial institutions, brokerage firms, and the media since 1999.

Investtech Invest is a UCITS-registered equity fund launched in January 2021 by Investtech.com AS. UCITS is a type of investment fund that complies with  European regulations and has extensive requirements regarding risk diversification, eligible investments, and frequent redemption opportunities for shareholders. The fund is a continuation of the investment company Investtech Invest AS, which was established by Investtech.com in 2010. Buying and selling fund shares take place through distributors such as Nordnet, Pareto, SBanken, and others.

Investtech aims to ensure that, where possible, all aspects of sustainability—including environmental, social, and economic considerations—are taken into account. The sustainability strategy must be viewed in conjunction with other internal governing documents, such as procedural frameworks and the overall business strategy.
Investtech Invest is classified as an Article 6 fund, meaning it does not actively integrate sustainability information into its investment process. However, it is still required to disclose the extent to which it considers sustainability risks.

2.1 Sustainability
Sustainability, as defined in the SFDR, generally refers to environmental, social, and governance (ESG) factors that can have a long-term impact on an investment’s value. SFDR does not explicitly define "sustainability," but it establishes a framework for how sustainability information should be reported and presented to investors.

Additionally, SFDR introduces the concepts of "sustainable investments" and the "EU Taxonomy," a classification system that identifies the extent to which economic activities can be considered environmentally sustainable. SFDR requires financial institutions to disclose how they consider sustainability in their investments.

3. CORPORATE GOVERNANCE
The company’s operations rely on the trust of customers, public authorities, and society as a whole. Investtech must provide objective and accurate information about its business and services in an open and honest manner. Employees must exhibit behavior that is perceived as trustworthy, honest, and fair and that complies with the norms, regulations, and laws applicable in society.

Employees at Investtech and the company as a whole:

• Must adhere to high ethical standards, good corporate governance, and strong business management.
• Have zero tolerance for corruption.
• Maintain open, honest, and clear communication with all stakeholders.

4. OPERATIONAL GOALS
4.1 Selection
It is fundamentally important that the companies included in the fund comply with international laws, norms, and conventions. Consequently, efforts are made to ensure that companies excluded from the investment universe of the Norwegian Government Pension Fund Global ("the Oil Fund") by Norges Bank, or those on the bank’s observation list, are not included in the fund.
The exclusion list is compiled by an independent ethics council commissioned by the Norwegian Ministry of Finance, which continuously evaluates companies on a global scale.

The Oil Fund’s exclusion and observation list includes companies where there is an unacceptable risk that they contribute to or are responsible for:

• Gross or systematic violations of human rights.
• Serious violations of individual rights in war or conflict situations.
• Sale of weapons to states engaged in armed conflicts that use these weapons in ways that constitute serious and systematic violations of international humanitarian law.
• Sale of weapons or military equipment to states covered by the sovereign bond exemption scheme.
• Severe environmental damage.
• Actions or omissions that, at an aggregate corporate level, lead to unacceptable greenhouse gas emissions.
• Gross corruption or other serious financial crimes.
• Other particularly severe breaches of fundamental ethical norms.

4.2 Integration of Sustainability Risk
Sustainability risk refers to the risk of environmental, social, or governance-related events or circumstances that may have a materially negative impact on an investment’s value if they occur.
The fund’s investment strategy is based on quantitative models that do not incorporate sustainability. The only integration of sustainability risk occurs through the exclusion of companies listed on the Oil Fund’s exclusion and observation list.
Investtech is a small company with a relatively simple business model, where sustainability-related risks are not considered to have a significant impact on operations or create conflicts of interest.

4.3 Assessment of Negative Impacts on Sustainability Factors
Sustainability factors include environmental issues, social issues, labor rights, and issues related to human rights and anti-corruption efforts.
At present, Investtech does not consider the potential negative impacts of investment decisions on sustainability factors. The fund’s investment strategy is based on quantitative models that do not include sustainability considerations.

5. OWNERSHIP AND RESPONSIBILITY
The CEO is ultimately responsible for ensuring that the strategy is followed. The sustainability strategy is also anchored in the Board of Directors, which will review and revise the strategy annually, or more frequently if necessary. The strategy is made known to all employees, and the latest version is always available on the company’s website. Each employee is responsible for ensuring compliance with the strategy in their daily work.

Last revised: 11.03.2025