Backing pre-seed and seed stage teams with a link to Norway

SFDR DISCLOSURES FOR SONDO CAPITAL AS, SONDO FUND 1 AS, AND SONDO FUND 2 AS

SFDR Article 3 Entity Level Policy on Sustainability Risk Integration

The firm has assessed sustainability risks in our investment processes. Based on our strategy, investment stage and available information, the firm currently assesses that sustainability risk is not materially relevant for our products/mandates in the pre-seed/seed phase.

Consequently, we do not integrate sustainability risks as standalone decision criteria beyond our ordinary financial and operational risk assessments.

Rationale for the Assessment

Stage and nature: In pre-seed/seed, key value drivers are primarily idea quality, team, product‑market fit, technology risk and financing risk. Decision-relevant and verifiable ESG data are typically limited or unavailable at this stage.

Data availability and verifiability: Lack of reliable, comparable and auditable ESG indicators for very early-stage companies reduces the utility of formal integration.

Risk–return profile: Idiosyncratic early-stage risks dominate the expected return profile; identified sustainability risks are not considered determinative for valuation or exit prospects within our mandate.

Consequences and Reservations

Should sustainability-related events nonetheless materialise, they may negatively affect risk/return. Such effects are handled through our ordinary financial and operational risk management.

The firm makes no commitment to promote environmental or social characteristics and has no sustainable investment objective.

SFDR Article 4 Principal adverse impact — Entity‑level stance

The firm does not consider principal adverse impacts of investment decisions on sustainability factors within its investment processes for current mandates.

Explanation: Stage and nature of investments: At pre‑seed/seed stages, investee companies typically lack reliable, comparable and auditable data required for PAI indicators. Business model risk, technology execution, product‑market fit, and financing risk are the dominant value drivers.

Data limitations: Standardised PAI metrics (e.g., GHG emissions, energy efficiency, social metrics) are commonly unavailable or non‑verifiable for very early‑stage companies, reducing the feasibility and usefulness of formal PAI consideration.

Mandate alignment: The firm's products/mandates pursue purely financial objectives and do not promote environmental or social characteristics. The expected idiosyncratic risk profile of early‑stage venture investments means PAI consideration is not determinative for decisions under our mandate.

Consequences and Reservations

The firm makes no commitment to consider or report on principal adverse impacts for current mandates.

Should sustainability‑related events nonetheless occur, their financial effects will be handled through the firm's ordinary financial and operational risk management. No representation is made that such handling will align with PAI frameworks.

SFDR Article 5 Remuneration policy

Fixed remuneration only: Employees receive fixed salary aligned with role, responsibilities, and market benchmarks. Pension and benefits: The firm provides statutory/contractual pension contributions and standard employee benefits.

Alignment with SFDR Article 5

Risk management consistency: The remuneration structure promotes sound and effective risk management and does not encourage excessive risk‑taking with respect to sustainability risks.

Sustainability risk stance: In line with our pre‑seed/seed strategy and available information, the firm does not integrate sustainability risks as standalone decision criteria. If sustainability‑related events nonetheless materialise, their effects are handled through ordinary financial and operational risk management processes.

Proportionality: The policy reflects the firm's size, internal organisation, and the nature, scope and complexity of activities.

SFDR Article 6 (Sondo Fund 1 AS and Sondo Fund 2 AS)

Integration stance

Based on the fund's strategy, stage focus and available information, sustainability risks are currently assessed as not materially relevant to investment decisions for this product. As such, sustainability risks are not integrated as standalone decision criteria beyond ordinary financial and operational risk assessments.

Rationale

At pre-seed/seed stage, decision-relevant and verifiable ESG data are typically limited or unavailable. Idiosyncratic early-stage risks (team, technology, market fit, financing) dominate expected return profiles. Standardised early-stage ESG/PAI metrics are commonly unavailable or non-verifiable, reducing feasibility and usefulness of formal integration.

Consequences

If sustainability-related events nonetheless occur, they may negatively affect the fund's risk/return profile. Such effects are handled through ordinary financial and operational risk management.

Version 1 20230620
Version 2 (current) 202510xx (TBC)