Responsible Investments Report 2024

Responsible Investments Report 2024

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Contents Facing Forward

3 5 5 6 7 8 9

ESG highlights

2024 at a glance

ESG highlights of the year

ESG Awards

Active in the global RI Community New investor initiatives 2024

Sustainability at Nordea

11 12 12 15 16 20 22 23 24 25 27 29 29 31 33 35 38

Responsible Investment approach

ESG Governance and Teams

Responsible Investment framework

Responsible Investment Strategies at NAM

Focus on NAM’s Private Strategies

Stewardship

Engagement

Voting

Stewardship Activities

Focus on Methane Engagement

ESG Focus Areas

Climate

Biodiversity

Human Rights

Good Governance

Outlook 2025

Nordea Nordea is the largest financial services group in the Nordic region (approx. 10 million personal customers and 600,000 corporate customers 1 and one of the biggest banks in Europe. We want to make a real difference – for our customers and for the communities in which we operate – by sharing our extensive expertise based on 200 years in the banking business. About Nordea Asset Management 2 Nordea Asset Management (NAM) is part of the Nordea Group. We are an active asset manager with a global business model, offering services to institutional clients in Europe, the Americas and Asia. We manage investments across the full spectrum of asset classes. Our third-party distribution franchise services a wide range of international fund distributors, including many of the leading global wealth managers. We distribute our products through banks, asset managers, independent financial advisors, insurance companies and family offices. Our client base is equally split between Nordea Group-related and external clients. With EUR 286bn (31 December 2024) in assets under management, we have been experiencing strong growth over the past decade. 1) As at 31.12.2024. 2) Nordea Asset Management it is the functional name of the asset management business conducted by the legal entities Nordea Investment Funds S.A. and Nordea Investment Management AB and their branches and subsidiaries. Nordea Investment Funds S.A. is the management company and Nordea Investment Management AB is the investment manager of all funds belonging to NAM. Reference to companies or other investments mentioned should not be construed as a recommendation to the investor to buy or sell the same but is included for the purpose of illustration.

RI Annual Report 2024

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Facing forward Steady at the helm: NAM is staying the course with sustainable investment

As we present this report in early 2025, the world of responsible investing continues to evolve rapidly. Indeed, we have witnessed continued demand for our responsible investment solutions despite ambiguity and skepticism in some quarters.

In 2024, NAM raised nearly €5 billion in new sustainability- focused mandates, demonstrating the trust our clients place in our ability to integrate sustainability considerations into robust investment strategies – and to their commitment to decarbon- ization and responsible investment. We are especially proud of the broad range of major mandates we secured across geographies. From a large German pension fund investing over €1 billion in our European Stars Equity Strategy to a major Northern European pension fund allocating more than €2 billion to our Global Impact Strategy; invest- ments also came in from the US, UK, France, Japan and beyond. These partnerships underscore the global appeal of our sustainability-focused offerings. In 2024, we witnessed par - ticular interest for customized solutions focused on decarbon- ization objectives, and we have worked with many clients to meet these needs. Our commitment to Responsible Investment extends beyond our products. Last year, we led 1393 engagements, including a collaborative effort representing over € 3.7 trillion in AuM

focused on improving disclosures and reducing methane emis- sions in the energy, utilities, and waste management sectors. NAM was awarded the prestigious PRI Award “Recognition for Action – Climate” for this effort. Other notable independent honours include "Fund of the Year" at the Environmental Finance 2024 IMPACT Awards for Nordea 1 – Global Impact Fund and “Best ESG European Equity Fund” at MainStreet Partners ESG Champions 2024 awards for Nordea 1 – European Stars Equity Fund. NAM was also ranked 4 th Best Asset Manager in the World for Respon- sible Investment Commitment by RIBI (Responsible Investment Brand Index 2024) based on both RI brand and RI commit- ment. Additionally, we became a signatory of the Operating Principles for Investment Management (OPIM) for our Global Impact Strategy, reinforcing our commitment to rigorous impact measurement and management practices. By year-end 2024, our ESG assets – comprising Article 8 and 9 funds under the EU's Sustainable Finance Disclosure Regula- tion – reached approximately €212 billion, representing over

RI Annual Report 2024

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70% of our total AuM. This reflects our firm-wide commitment to responsible investing and our clients' continued appetite for sustainable financial products. Looking ahead to 2025, we are embracing new regulatory standards, including the ESMA naming requirements, which will further distinguish NAM's exceptional product lineup in the marketplace. Since NAM SFDR Article 8 and 9 funds already uphold a high standard of sustainability, we expect marginal, or no impact on our funds and their investment universe. At the time of writing this report, we are in the process of getting reg- ulatory approval to add or keep the term “sustainable” for many funds, both on the equity and fixed income side, in par - ticular for our flagship ESG STARS range and our responsible enhanced BetaPlus family.

As we move forward, NAM remains committed to delivering investment strategies that generate strong financial returns while contributing positively to society and the environment. We believe that responsible investing is not just about risk miti- gation, but about capitalizing on the opportunities presented by the global transition to a more sustainable economy. We invite you to explore this report, which details our achieve- ments, strategies, and outlook in responsible investing. Thank you for your continued trust and partnership as we work together towards a more sustainable financial future.

Nils Bolmstrand, CEO of Nordea Asset Management

ESG highlights

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2024 at a glance

ESG Offering

Assets under Management

Products

New reports in 2024

1 Impact Report 1 Thematic Report

€ 286 bn total AuM 74% In RI solutions

259 Art. 8 funds 3 10 Art. 9 funds 3

17 ESG Reports

ESG Capabilities

ESG Resources

Engaged 5

Voted

4 Governance Committees 28 Dedicated ESG analysts 4

1393 Engagements

~3550 General meetings in 2024

58% E 19% S 23% G

ESG Leadership

Initiatives

Awards 6

Labels 8

31 International investor initiatives

8 ESG Awards won 11 ESG Awards shortlisted 7

2 European ESG labels

Net Zero Targets

By 2025

By 2030

By 2050

80% of Top 200 constributors to

100% of Top 200 constributors to financed emissions to be Paris-aligned or engaged to become so 50% reduction of WACI 9 across listed equity and corporate bonds

Net zero emissions across all assets under management

financed emissions to be Paris- aligned or engaged to become so Phase out investments in coal- related companies without plans to achieve a full exit from coal by 2040

3) According to European SFDR classification. 4) Data as of 31.03.2025. 5) E,S and G categorizations are not mutually exclusive. For ana - lytical purposes, we count such instances separately under each applicable category. The resulting figures are then normalized to repre - sent proportions of total engagements. 6) More information on ESG awards on pages 5 – 6. 7) Nominated in 24 categories, excluding cat - egories won. 8) More information on labels on page 19. 9) Weighted Average Carbon Intensity (tCO 2 e/USD million) measures a portfolio’s exposure to carbon intensive companies.

ESG highlights

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ESG highlights of the year

In 2024, we remained focused on reinforcing our ESG credentials and capabilities. We strengthened our position in impact investing by subscribing to the Operating Principles for Impact Management (OPIM) and adhering to the GIIN initiative. We continued to drive real- world decarbonization through our climate strategies and proprietary tools.

Playing our part in real world decarbonisation Investors increasingly recognize climate change as a global crisis threatening the environment, society and economy. The last few years we have seen important steps towards adopt- ing climate policies with a positive impact on achieving net zero emissions targets by 2050. At Nordea Asset Manage- ment, we do not believe we can achieve net zero purely by avoidance and exclusion. Climate change has been a strategic focus for us since becoming a signatory to the UN-supported Principles for Responsible Investment (PRI) in 2007. In 2024, we have made our proprietary Forward Decarbon- ization tool available to all our investment boutiques. This tool offers a forward-looking view of companies' potential decarbonisation trajectories, helping portfolio managers make informed decisions on engagement and allocation to meet strategy-specific decarbonisation objectives. Our commitment to climate action was further recognized in late 2024 with our Methane Engagement Campaign receiving the 'Recognition for Action – Climate' award at the PRI Awards ceremony in Toronto, Canada. Expanding our capabilities In 2024, we have expanded our Sustainable Thematic offering and launched two Article 9 Labelled Bond Funds: Nordea 1 – European Sustainable Labelled Bond Fund and Nordea 1 – European Corporate Sustainable Labelled Bond Fund. These funds help asset allocators build sustainable fixed income port - folios and demonstrate NAM's commitment to ESG innovation. Moreover, our Responsible Investments team have developed a proprietary Sustainable Investments (SI) approach to sustain- able labelled bonds to ensure SFDR compliance and maintain high standards, using sophisticated models to evaluate ESG credentials of issuers. During 2024, we onboarded Iceberg Data Lab as an additional

biodiversity data provider, enhancing our commitment to bio- diversity and nature through their Corporate Biodiversity Foot- print (CBF) offering. The CBF quantifies a company's biodiver - sity impact by analyzing factors like land use, climate change, and pollution, providing investors and corporations with actionable insights for integrating biodiversity considerations into investment decisions and risk assessments. We're continu- ously reviewing new data sets and data providers to enhance quality and biodiversity and nature-related assessments. Additionally, we have set a corporate exclusion on palm oil: NAM does not invest in palm oil producers 10 that lack an RSPO certification target for their holdings and estates. Furthermore, companies with an RSPO target but less than 50% RSPO certi - fication 11 are also restricted. Maintaining our ESG credentials Our 35+ years of experience in sustainable investing continues to earn recognition. In 2024, we ranked 4th global asset man- ager ESG Brand in the RIBI Report, demonstrating our com- mitment to responsible investing and sustainable development. Additionally, our Nordea 1 – Global Impact Fund won "Fund of the Year – Listed Equity" at the Environmental Finance Impact Awards 2024. Our credentials extend to international ESG-labels and in 2024, we have secured Label ISR and Towards Sustainability labels for some of our funds, recognizing our ESG products. We maintained our UK Stewardship Code signatory status, meet- ing the highest disclosure and reporting standards in the UK. On top of this, all our funds received ESG4Real certification, confirming compliance with basic RI demands, including exclu - sions, norms, conventions, ESG criteria and engagement that asset managers shall comply with. Additionally, some funds obtained Nummus Ethics Certification, aligning with CEI's ethi - cal guidelines. 12

10) Palm oil producers are defined as having >10% revenue threshold from palm oil. 11) RSPO: Roundtable on Sustainable Palm Oil. 12) CEI´s ethical guidelines: CEI Guidelines - Nummus.Info.

ESG highlights

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ESG Awards

At Nordea Asset Management, we are proud to report a very important year in 2024 for our responsible investing efforts. Our commitment to ESG principles has earned us significant global recognition.

Nordea Asset Management Awards

Our achievements in 2024 include the PRI Award “Recognition for Action – Climate” for our Methane Engagement Campaign, demonstrating our leadership role in addressing critical climate issues. We also achieved a strong ranking in the Responsible Investment Brand Index (RIBI) 2024, performing well in both global and Scandinavian markets.

Fund Awards

Sustainable STARS Funds

Our Sustainable STARS Funds series received notable recognition with our Nordea 1 – Global Sustainable Stars Equity Fund 13 named Equities Manager of the Year at the European Pensions Awards 2024. Additionally, our Nordea 1 – European Sustainable Stars Equity Fund 14 was recognized as the Best ESG European Equity Fund by Mainstreet, while our Nordea 1 – Emerging Sustainable Stars Ex China Equity Fund 15 received the SRI Special award for Emerging Markets Equity from Gruppo 24 Sole in Italy.

Sustainable Thematic Funds

Our Nordea 1 – Global Climate and Environment Fund won the Best Environmental Fund in Spain by the Expansión/Allfunds ESG Awards, and Best Environmental/Climate Fund in the UK at the Investment Week Sustainable Investment Awards 2024.

Finally, our Nordea 1 – Global Impact Fund was nominated as Fund of the Year on Listed Equity by the Environmental Finance Impact Awards 2024.

13) With effect as of April 8th the sub-fund is renamed from " Nordea 1 – Global Stars Equity Fund" to "Nordea 1 – Global Sustainable Stars Equity Fund". 14) With effect as of April 8th the sub-fund is renamed from " Nordea 1 – European Stars Equity Fund" to "Nordea 1 – European Sustainable Stars Equity Fund". 15) With effect as of April 8th the sub-fund is renamed from " Nordea 1 – Emerging Stars Ex China Equity Fund" to "Nordea 1 – Emerging Sustainable Stars Ex China Equity Fund".

ESG highlights

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Active in the global RI community

Contributing actively to industry-wide responsible investment discussions and promoting best practices across the investment community are key components of our ESG work.

Collaborative Engagements We recognize the value of collaborative engagements in our active ownership strategy, as they allow us to share industry perspectives and expand our impact. In 2024, we participated in 672 collaborative engagements, leading 103 of these. Key collaborations focused on Climate Action 100+, Nature Action 100+, Corporate Human Rights Benchmark, Oil & Gas Methane Partnership 2.0 (OGMP), and Pharma Industry Engagement. Complementing these efforts, we also individu - ally engaged with 721 companies during the same period, demonstrating our commitment to both collective and direct approaches in promoting sustainable practices. We continued our Methane Engagement campaign, which was awarded the "Recognition for Action – Climate" award at the Principles for Responsible Investment (PRI) Awards cer- emony in Toronto, Canada. We have also signed the Investor Action on AMR (IAAMR) Public Investor Statement, together with other institutional investors, to stress our concerns regarding antimicrobial resistance (AMR) as a systemic risk to investment portfolios, economic stability and society. Through these collaborative initiatives, we continue to leverage our joint influence to driving positive change, promoting sustain- able practices, and creating long-term value for our clients and stakeholders. Academic Collaborations Eric Pedersen, our Head of Responsible Investments, holds academic positions at Copenhagen Business School and Bos- ton University. In 2024, the Responsible Investment team col- laborated with students on research projects, delivered guest lectures, and supported the development of research papers on regulatory and transition dynamics. As an example, the team has contributed to the IGCC report 16 on methane emis- sions from fossil fuel operations, following their work with the Oil & Gas Methane Partnership 2.0.

Participating in investor initiatives is a way for us to exchange knowledge, shape the sustainable finance industry and to benchmark and develop our own ESG approach and frame- work. During 2024, we were active in 31 investor initiatives across a broad range of ESG topics. We were also active in sev- eral Sustainable Investment Forums (SIFs) throughout Europe and participated in numerous engagements in collaboration with other investors. While these initiatives and collaborative actions are an extremely important part of our work, we recognize that our role and responsibility in the RI community extend beyond these initiatives. We aim to engage with our stakeholders, to educate and learn. We do this by participating in events and discussions, contributing to publications, engaging with our clients and fostering academic collaborations. Industry Committees Representation We continued our active engagement in key industry initia- tives committees throughout 2024. As founding members of the ISSB Investor Advisory Group (formerly SASB's Investor Advisory Group), we helped shape global sustainability dis- closure standards, with our Head of Responsible Investments, Eric Pedersen, representing NAM. We lead company disclosure engagements and demonstrate ISSB standards' investor appli- cations across scenarios. Additionally, we have been supporters of TCFD (now closed), whose reporting requirements were incorporated into the ISSB standard, which provides a foun- dation for climate-related financial disclosures, encouraging companies to report on climate risks and opportunities most relevant to their business activities. Our Head of Climate and Nature Team, Cecilia Fryklöf, partici- pated on the steering committee of the Investor Initiative on Hazardous Chemicals (IIHC), addressing environmental and financial risks associated with chemical use. Since 2018 we have held a unique position as the sole asset manager on the Advisory Board of the Pharmaceutical Supply Chain Initiative, promoting responsible practices in the industry.

16) IGCC Report: Momentum: Addressing methane emissions from fossil fuel operations.

ESG highlights

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New investor initiatives 2024

As a responsible investors, we actively participate in investor initiatives on various ESG topics. We are currently part of 31 initiatives, including 2 new initiatives that we joined during 2024.

New RI Initiatives Global Impact Investing Network (GIIN) Operating Principles for Impact Management (OPIM) Investor Statements Investor Sign-on Comment Letter Environmental and Climate Change Canada Methane (ECCC)

European Union Emissions Reduction Target Advocacy Antimicrobial Resistance (AMR) Investor Statement Investor Statement on Shareholder Rights Petrochemical Industry Sustainability Statement Investor Statement to end plastic pollution

Global Impact Investing Network (GIIN) We became a member of the Global Impact Investing Net- work (GIIN), gaining access to valuable resources, networking opportunities with leading investors, and the ability to shape the impact investing industry. This initiative and framework guide our impact assessment, reporting, and overall invest- ment process, ensuring we contribute effectively to solving global issues while signaling credibility. Operating Principles for Impact Management (OPIM) We have signed on the Operating Principles for Impact Man- agement (OPIM). The Impact Principles provide a common framework for shaping and aligning with industry best prac- tices and promote transparency, discipline, and credibility for impact management practice in capital markets. There are nine Operating Principles for Investment Management (the “Principles”) which offer investors a comprehensive set of rig - orous practices that guide the integration of impact.

As an OPIM signatory, NAM has aligned its Global Impact Strategy with the principles and commits to annual disclosure statements. Independent verification ensures compliance, pro - moting transparency and credibility in impact investing. This practice supports the growth of responsible investing while maintaining integrity and external credibility in the market.

By participating in this global initiative, we aim to contribute to greater clarity, discipline and accountability to the field of impact investing. Nils Bolmstrand, CEO, Nordea Asset Management

ESG highlights

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Letters and Statements Investor Sign-on Comment Letter Environmental and Climate Change Canada Methane (ECCC) On February 14th 2024, we commend ECCC’s efforts to adopt cost-effective regulations to achieve at least a 75% reduction in oil and gas methane emissions by 2030 from a 2012 baseline and urge you to move swiftly to adopt comprehensive final standards. European Union Emissions Reduction Target Advocacy On 21st of March 2024, a coalition of institutional investors submitted a formal letter to EU Environment and Climate ministers, advocating for an ambitious greenhouse gas emis- sions reduction target of 90% by 2040 (baseline year 1990). The communication emphasizes that such a target is crucial for enhancing the EU's economic resilience, ensuring energy secu- rity, and maintaining global competitiveness in the transition to a low-carbon economy. Antimicrobial Resistance (AMR) Investor Statement On 22nd of May 2024, as part of the Investor Action on AMR Initiative, a group of institutional investors released a public statement highlighting antimicrobial resistance as a critical systemic risk. The document outlines AMR's potential impact on investment portfolios, economic stability, and global public health.

Investor Statement on Shareholder Rights On May 28, 2024, Nordea Asset Management, along with other investors managing $4.8 trillion in assets, signed the Investor Statement on Shareholder Rights. This statement supports the SEC's role in arbitrating shareholder proposals and expresses concern over litigation that may discourage sustainability-relat- ed proposals. It advocates for constructive dialogue between companies and investors to address concerns, rather than resorting to legal action that could undermine shareholder advocacy in the U.S. Petrochemical Industry Sustainability Statement On 11th of July 2024, a consortium of 70 leading financial institutions, collectively managing or advising USD 6.8 trillion in assets, issued a joint statement addressing the petrochemi- cal sector. The declaration called for a decisive shift towards sustainable practices, emphasizing the reduction of fossil fuel dependency and the elimination of hazardous chemicals in plastics production. Investor Statement to end plastic pollution In Oct 2024, NAM joined 179 other financial institutions in signing an investor statement supporting a legally binding international treaty to end plastic pollution. The statement, collaboratively drafted by UNEP FI, PRI, Finance for Biodi- versity Foundation, Business Coalition for a Global Plastics Treaty, VBDO, and CDP, outlines the financial sector's perspec - tive on essential components for an effective global plastics agreement.

Sustainability at Nordea

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Sustainability at Nordea

Nordic values are an essential part of Nordea Asset Management’s business culture, guiding us in everything we do.

established objectives to reduce emissions across both our lending and investment portfolios as well as our internal opera- tions by the end of 2030. Nordea Group’s sustainability work is led by the Group Sustain- ability team. This includes everything from setting and meeting our internal sustainability targets, from resource usage to diversity, and also integrating sustainable considerations into the products and services across the Group. At NAM level, the Responsible Investment (RI) team carries out research on the integration of environmental, social, and governance (ESG) aspects into our investments. The two boxes below summarise some of our key sustainability metrics. More information about Nordea Group’s sustainability efforts can be found in Nordea’s Annual Report 2024.

Sustainability is embedded across Nordea’s business strategy, backed by measurable targets, strong governance, and a broad sustainability offering. Nordea Group has long and solid experi- ence within Sustainable Finance and we are fully committed to – and actively working on – making the financial sector more sustainable. As a leading Nordic bank, we have the capacity to support the transition to net zero – via our customer offerings, through our lending and investment decisions and by reducing the emis- sions from our internal operations and supply chain. Therefore, our business objective is to achieve net-zero emissions across our value chain in terms of scope 1, 2 and 3 emissions by the end of 2050 at the latest. In addition to our net-zero commit- ment for 2050, we see interim targets as essential components of the global effort to limit warming to 1.5°C. We have therefore

Diversity and inclusion

Carbon footprint from internal operations (2024) Nordea has committed to achieving net-zero carbon emissions by 2050 across investment portfolios and internal operations

Age distribution in the total workforce

Gender balance

18%

25%

Board of directors

40%

60%

CO 2

Group Leadership Team

57%

41%

59%

Total CO 2 e emissions:

1.981 GHG Emission Intensity:

People leaders

44%

56%

below 30 years old 30–50 years old above 50 years old

23,932,784 t CO 2 e , representing a 29% reduction from the 2019 baseline

Total workforce

51%

49%

Nordea Asset Management

t CO 2 e /monetary unit

36%

64%

Source: Nordea Annual Report 2024., Nordea Investment Management AB.

Responsible Investment approach

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Responsible Investment approach

ESG Governance and Teams

Responsible Investments Team

Formed in 2009, Nordea’s RI team is one of the most highly- regarded in Europe in terms of ESG analysts. It is composed of 28 analysts, who work closely with their respective portfolio management teams in Copenhagen, Stockholm, Oslo, Helsinki and Singapore. Besides working closely with the investment boutiques managing ESG products and setting the framework for the development of new quantitative tools and data sources. The team carries out ESG research, active ownership activities, and represents NAM in international RI initiatives. We are con- tinuously developing our RI approach in line with the increasing complexity, depth and scope of application of ESG methods, in order to maintain NAM’s leadership in the area. The team provides a broad RI coverage with a particular focus on our ESG Flagship Strategies, working closely with their respective portfolio management teams. The RI team often participates in client meetings and ESG conferences to share its latest insights and findings. It also leads ESG training (e.g. climate workshops) both internally and for clients.

cedures, proxy voting, firm-level PAI process as well as for driving the Responsible Investment Committee agenda • The Climate & Nature cluster maintains focused exper- tise and analysis of climate change and biodiversity fac- tors and policies, implementation, engagement campaigns and reporting (e.g. Task Force on Climate related Financial Disclosures (TCFD) recommendations). Additionally, the team supports on developing tools and solutions for clients and PMs • The Sustainability Research cluster carries out company and sector specific ESG research and engagement for NAM’s ESG funds, as well as ESG product development. This includes our proprietary ESG scoring, which is an integral part of our ESG-enhanced strategies such as the Sustainable STARS funds • The ESG Quant cluster develops and maintains NAM’s proprietary ESG scoring tool and platform, as well as other advanced applications of ESG data Additionally, from October 2024, three dedicated specialists now integrate the Responsible Investments Advice Team which is responsible for the sustainable savings advice concepts implemented in Nordea Bank and also align the strategy behind products distribution, for customers with sustainability preference.

The RI team’s various functions and main responsibilities can be divided into four clusters:

• The Investment Stewardship cluster is responsible for NAM’s engagement framework, including escalation pro-

Responsible Investments Team

Eric Pedersen Head of Responsible Investments

Morten Bo ESG Quant

Katarina Hammar Investment Stewardship

Cecilia Fryklöf Climate and Nature

Rikke Berg Jacobsen Sustainability Research

+4 Analysts

+8 Analysts

+5 Analysts

+3 Analysts

Eva Palmborg Responsible Investment Advice

+2 Senior Analysts

Responsible Investment approach

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ESG and Responsible Investments Committees

At Nordea Asset Management (NAM), we have established a robust structure for both oversight and implementation of respon- sible investment practices. This structure ensures that our commitment to ESG principles is embedded throughout our organiza- tion, from the Board of Directors to individual investment teams.

ESG Committee Following a firm wide ESG project carried out in 2021-22, in 2023 we created an ESG Committee, supported by an operational forum, to secure the governance of our ESG related methods and principles. An ESG Operational Forum facilitates discussions and secures alignment and coordination on ESG matters across the NAM internal value chain, ensuring that the relevant decisions-are brought to the ESG Committee for approval.

Chair AM CEO Nils Bolmstrand

Head of Responsible Investments (non-voting)

Head of Multi Assets

Head of Trading & Operations

Head of Equities & Fixed Income

ESG Committee

The ESG Committee is also responsible for the content of and adherence to our Responsible Investment Policy:

Head of Institutional & Wholesale Distribution

• •

Drive NAM’s ESG Strategy

Head of Technology

Approve entity level ESG principles, policies and statements

Head of NAM Governance

Head of Product Office

• Approve significant changes to ESG methodologies and product strategies • Secure good governance and proper handling of potential conflict of interest matters in the ESG area

Responsible Investment Committee Our Responsible Investment Committee (RIC), which is comprised of the NAM CEO and Senior NAM executives, ensures compliance with our RI Policy by monitoring engagements and deciding on the level of engagement in companies that violate international norms or companies where an engagement is deemed relevant for other rea- sons. Additionally, RIC also submits recommendations on companies to be included/excluded from the Exclusion List (decision is taken by the CIO’s). The RI Committee acts on behalf of all actively managed funds. Day-to-day manage- ment of RI issues is handled by the RI team.

Chair AM CEO Nils Bolmstrand

Head of Equities & Fixed Income

Head of Institutional & Whosale Distribution

Responsible Investments Committee

Head of Responsible Investments

Head of Product Office

Selected representatives from relevant business areas (non-voting) +

Responsible Investment approach

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Corporate Governance Committee The Corporate Governance Committee is a key body responsible for overseeing and approving NAM's corpo- rate governance principles and voting decisions. It includes board members from the Nordea Fund company, provid- ing high-level oversight and independent decision-making. The committee is chaired by one of the external board members to ensure impartiality. In sum, its key responsi- bilities include: • Annually reviewing and approving the Corporate Governance Principles, which guide NAM's voting activities • Making decisions on voting matters that are escalated to the committee, particularly in cases of potential conflicts of interest • Ensuring that voting decisions are made in the best interests of clients Proxy Voting Committee The Proxy Voting Committee (PVC) is responsible for driv- ing voting decisions and managing conflicts of interest related to voting activities for client mandates. In sum, its key responsibilities include: • Implementing the Corporate Governance Principles for client mandates • Making voting decisions • Managing potential conflicts of interest in proxy voting for client portfolios

Chair External Board Member

External Board Member

External Board Member

Corporate Governance Committee

Head of Investment Stewardship

CEO of the fund company

Chair Head of Investment Stewardship

Head of Equities & Fixed Income

Head of NAM Compliance

Proxy Voting Committee

Head of Multi Assets

Responsible Investment approach

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Our Responsible Investment framework

At NAM, we believe it is our fiduciary duty to deliver returns with responsibility. Our commitment to be a responsible asset manager is not new. We launched our first sector-screened fund in 1988 and we were an early adopter of Responsible Investment (RI), signing the UN Principles for Responsible Investment (PRI) back in 2007. By the end of 2024, Responsible Investment Solutions comprise over 74% of NAM’s AUM.

NAM has developed policies and procedures to ensure that the companies we invest in meet our expectations related to ESG performance, and that ESG and sustainability risks are managed in all our investment processes. These include both corporate-level RI approaches ("overlays") and product-specific approaches. NAM’s RI Policy defines our position on sectors that are linked to material ESG issues, going beyond the international norms and conventions. This helps to ensure that the companies we are invested in meet our expectations of sound ESG perfor-

mance. The policy describes the stance we take on a number of areas within human rights, climate change, biodiversity and good governance. Depending on the nature and gravity of in- dividual cases, breaches can trigger engagement or exclusion. The RI Policy is publicly available on our website. Our corporate-level RI overlays include norms-based screening, active ownership activities and NAM-wide exclusions, as well as Sustainability Risk Integration. We also have product specific RI approaches that take a step further into enhancing ESG integration.

A comprehensive RI Framework including various forms of RI

NAM total AUM € 286.0 bn

Nordea Asset Management corporate level RI “overlays” applicable to all funds

All actively managed funds € 234 bn

Sustainability Risk Integration 18

Norms-based screening

Active Ownership

Corporate-level Exclusion List 17

ESG products Article 8 and 9 funds – according to SFDR classification

~ 74% of total AUM € 212 bn

Responsible Focus € 30.9 bn Sustainable Thematic € 8.7 bn Engagement Focus € 0.9 bn

Our Flagship ESG strategies 19

21 Responsible Focus

8 Sustainable Thematic Focus

2 Engagement Focus

17) Over 260 companies. NAM’s Exclusion List available here. 18) Integration of Sustainability Risks in the respective funds decision-mak- ing process. Every investment boutique has access to NAM's proprietary ESG Model and ESG analysis from the RI team and ESG data from external providers via our proprietary ESG data platform. 19) These only refer to Nordea 1 and Nordea 2 Funds.

Responsible Investment approach

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Responsible Investment Strategies at NAM

NAM's Responsible Investment flagship solutions feature distinct offerings. Our Responsible Focus range which select high-quality companies with strong ESG profiles, aiming for long-term financial value. The ESG Thematic range which allows investors to target specific sustainability aspects. Finally, our Engagement Focus funds that actively engage on material ESG issues to drive positive impact.

Our Responsible Focus Strategies Sustainable STARS strategies – Tomorrow’s winners Our Sustainable STARS range is built on the belief that companies and issuers that integrate both ESG and finan - cial metrics into their strategic decisions will be tomorrow’s winners. In these strategies, we aim to beat the benchmark through investing in companies or bonds that meet NAM’s ESG standards. Every investment in our Sustainable STARS strategies is exam- ined through both an ESG and a financial lens. Our ESG ana - lysts work closely with the investment teams to identify mate- rial sustainability risks and opportunities relating to the com- panies’ medium- to long-term operational performance and market positioning, and the results of their analysis feed into proprietary ESG tools that are integrated into the investment process. Active ownership and engagement are an important part of the Sustainable STARS investment approach. Our RI team and investment boutiques operate in close collaboration to engage in productive dialogues with many of our Sustain- able STARS holdings. The Sustainable STARS range covers a wide scope of regions and asset classes.

Today 20 we manage approximately 270 funds that incorporate additional ESG filters and policies beyond our corporate over - lays. These funds are classified as either Article 8 or 9 as per European Sustainable Finance Disclosure Regulation (SFDR). All our Article 8 and 9 funds consider PAI on sustainability fac- tors as part of their investment processes. As a result, they are all eligible under MiFID II for selection by clients with sustain- ability preferences. Going a step further, we offer specialized ESG flagship strate - gies, including the Responsible Focus Range, which encom- passes our ESG Sustainable STARS Funds and BetaPlus Enhanced Sustainable Funds; the ESG Thematic range and Engagement Focus Funds. The Responsible Focus Strategies employ full ESG integration and positive selection, while the ESG Thematic strategies seek solutions to specific sustain - ability challenges, such as our Global Climate and Environment Fund, one of the largest article 9 funds in Europe 21 . Finally, our Engagement Strategies are built on the belief that engage- ment can support companies transitioning to more sustainable business models, with two funds actively engaging: one on Climate and the other in Diversity & Inclusion (D&I) material topics. Our credentials extend to international ESG labels such as Label ISR and the Towards Sustainability Label.

20) Date as of 30.04.2025. 21) As of 15.10.2024, Source: © 2024 Morningstar, Inc. All Rights Reserved as of 15.10.2024. Morningstar European Fund Family 100. Open-ended and exchange traded funds for sale in Europe.

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BetaPlus Enhanced Sustainable Strategies NAM's BetaPlus Enhanced Sustainable Equity Strategies are active and cost-effective long-only solutions aiming to deliver con - sistent excess returns, limited active risk, and very strong ESG features. The strategies employ a proprietary quantitative, multi-factor framework that capitalizes on market inefficiencies to generate alpha. By systematically identifying the most effective factors across various market segments, BetaPlus Enhanced Sustainable Equity Strategies construct portfolios aimed at outperforming traditional market-cap weighted indices while integrating rigor- ous ESG criteria, including extensive exclusions and decarbonization targets, without necessitating benchmark changes. This approach enables valuable sustainability outcomes while pursuing consistent excess returns. Managed by a team with over 15 years of experience and more than €60 billion in assets under management 22 , the strategies have established themselves in the enhanced index solutions space. In an investment landscape increasingly dominated by pas- sive strategies, they provide a sophisticated active alternative that combines the benefits of broad market exposure with the potential for outperformance and integration of sustainability features. Our Sustainable Thematic solutions – Building a better future We also offer a range of thematic strategies that focus on specific sustainability challenges aligned with the UN's Sustainable Development Goals (SDGs), to tackle the most pressing social and environmental challenges. The climate crisis is one of the greatest challenges of our time. But climate change has many faces, and it cannot be separated from social problems, which are often drivers of environmental issues. Significant economic, societal and institutional changes are needed to combat these challenges. Our thematic solutions are crafted to encompass the full spectrum of these complex issues, providing investors with opportunities to contribute to meaningful change while seeking financial returns. By focusing on specific sustainability themes, we aim to chan - nel capital towards innovative companies and projects that are at the forefront of developing solutions to global challenges, from renewable energy and resource efficiency to sustainable agriculture and social inclusion:

Sustainable Thematic Products

Environment

Environment & Social

Social

Global Climate & Environment Strategy

Global Impact Strategy

Global Social Empowerment Strategy

Investment Themes: Resource Efficiency; Environmental Protection and Alternative Energy

Investment Themes: Strong Communities; Resilient Economy; Livable Planet

Investment Themes: Vital Needs; Inclusion; Empowerment

Global Sustainable Listed Real Assets Strategy

Investment Themes: Environmental Stewardship; Societal Stewardship ; Technological Evolution

22) Nordea Investment Management AB. Data as of 31.12.2024.

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Our Engagement Focus Strategies – Widening our horizons We truly believe that engagement can support companies transitioning to more sustainable business models. Three years ago, we have created a new fund family, focusing only on Engagement Strategies, comprising of two different ones: the Nordea Global Climate Transition Engagement Strategy 23 , which supports higher-emitting companies in crucial industries on their sustainable transition, and the Nordea Global Diver- sity Engagement Strategy, which guides diversity laggards to become tomorrow’s diversity leaders. Nordea 1 – Global Diversity Engagement Fund The Nordea 1 – Global Diversity Engagement Fund aims to capitalize on the growing awareness of Diversity and Inclusion (D&I) in society. Research consistently shows that companies with at least 30% women in executive leadership tend to out - perform financially, benefiting from stronger decision-making, innovation, and risk management 24 . This 30% threshold is widely recognized as the tipping point for meaningful impact and is the primary standard we apply to our fund. However, we also consider companies with at least 20% women in leader - ship if they demonstrate positive progress towards greater diversity. To assess companies' D&I status, we evaluate four key pillars: Leadership Diversity, Talent Pipeline, Inclusion, and Diversity Change. This assessment allows us to categorize companies from Leaders to Laggards based on their D&I profiles. Our investment strategy combines data-driven analysis with tradi- tional fundamental bottom-up analysis, focusing on both cur- rent D&I Leaders and promising companies open to improve- ment. Additionally, we actively engage with companies where opportunities arise to enhance their diversity efforts and unlock shareholder value. By maintaining a threshold of 30% minority gender in leadership positions and selecting top-performing companies in each segment, we offer investors an opportunity to participate in D&I-focused investing. This approach aims to capture the dual benefits of enhanced financial performance and positive societal impact

Nordea 1 – Global Climate Transition Engagement Fund 23 In 2022, Nordea launched the Global Climate Transition Engagement strategy, which targets companies in sectors often overlooked by the market due to their less favorable carbon emission profiles. Despite this, we recognize that these companies can play a pivotal role in the energy transition. Our team at NAM, identifies opportunities for real-world decarbon - ization through a structured engagement approach with these businesses. We believe that many of these companies simply need the right guidance and expertise to unlock their ecologi- cal potential, reveal their hidden value potential, and attract investments. As such, engaging on material environmental issues forms the core of our investment process and in 2024, we have conducted over 80 interactions with our portfolio companies. We have also developed a Forward Decarbonization Tool to assess companies' potential future greenhouse gas emissions trajectories, enhancing our systematic consideration of decar- bonization paths. This proprietary tool provides a forward- looking view of direct (scope 1) and indirect (scope 2) emis- sions. Our conviction in decarbonization and climate transition investing has strengthened, as we see growing interest and investments in this area. We are that our climate capabilities will continue to support our dual objective of generating share- holder value while contributing to a greener future. 25

23) With effect as of April 8th the sub-fund is renamed from " Nordea 1 – Global Climate Engagement Fund" to "Nordea 1 – Global Climate Transition Engagement Fund". 24) McKinsey & Company, “Diversity matters even more: The case for holistic impact” (2023), MSCI ESG, “Women on Boards and Beyond: 2024 Progress Report”. 25) There can be no warranty that an investment objective, targeted returns and results of an investment structure is achieved. The value of your investment can go up and down, and you could lose some or all of your invested money.

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Sustainable Stars Equity Funds

Towards Sustainability Label 26

Label ISR 27

Nordea 1 – European Small and Mid-Cap Sustainable Stars Equity Fund Nordea 1 – Emerging Sustainable Stars Equity Fund Nordea 1 – North American Sustainable Stars Equity Fund

Nordea 1 – Nordic Sustainable Stars Equity Fund Nordea 1 – Global Sustainable Stars Equity Fund Nordea 1 – European Sustainable Stars Equity Fund Nordea 1 – Asian Sustainable Stars Equity Fund

Nordea 1 – Global Climate and Environment Fund Nordea 1 – Global Social Empowerment Fund Nordea 1 – Global Impact Fund Nordea 1 – Global Sustainable Real Assets Fund Nordea 1 – European Corporate Sustainable Labelled Bond Fund Nordea 1 – European Sustainable Labelled Bond Fund Sustainable Thematic Nordea 1 – Global Climate Transition Engagement Fund Nordea 1 – Global Diversity Engagement Fund Engagement Focus Nordea 1 – European High Yield Sustainable Stars Bond Fund Nordea 1 – European Corporate Sustainable Stars Bond Fund Nordea 1 – Global High Yield Sustainable Stars Bond Fund Nordea 1 – North American High Yield Sustainable Stars Bond Fund Nordea 1 – US Corporate Sustainable Stars Bond Fund Sustainable Stars Fixed Income Funds

BetaPlus Enhanced Sustainable

Nordea 2 – BetaPlus Enhanced Swedish Sustainable Equity Fund Nordea 2 – BetaPlus Enhanced Japanese Sustainable Equity Fund Nordea 2 – BetaPlus Enhanced Global Sustainable Equity Fund Nordea 2 – BetaPlus Enhanced Emerging Markets Sustainable Equity Fund Nordea 2 – BetaPlus Enhanced European Sustainable Equity Fund Nordea 2 – BetaPlus Enhanced North American Sustainable Equity Fund Nordea 2 – BetaPlus Enhanced Global Sustainable Small Cap Equity Fund Nordea 2 – BetaPlus Enhanced Global Developed Sustainable Equity Fund

26) We have received recognition from the Belgian Central Labelling Agency in the form of “Towards Sustainability” label. The label was launched in 2019 and it aims to install trust and reassure potential investors that the financial product is managed with sustainability in mind and is not exposed to very unsustainable practices, without requiring of investors to do a detailed analysis themselves. For more information on the “Towards Sustainability” label, visit towardssustainability.be. 27) Label ISR is created and supported by the French Finance Ministry. The label’s goal is to increase the visibility of SRI products among savers in France and Europe. For more information on the Label ISR, visit lelabelisr.fr/en/what-sri-label/.

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Focus on NAM’s Private Strategies

ESG in the private markets space and the opportunities the asset class provides.

Private market investors are capitalizing on these opportunities in various ways:

Environmental, Social, and Governance (ESG) considerations have become increasingly prominent in private markets as the asset class offers unique opportunities for meaningful ESG implementation and value creation. The structural nature of the private market investment allows for integrating ESG factors more systematically into the investment process, from initial due diligence through ongoing asset management. The long- term nature of the investments (typically 5-10 years) and the ownership levels enables another layer of ESG improvement and engagements over time. All of this provides the investors with a method to leverage the ESG opportunities in measur- able ways. While ESG integration continues to evolve, data indicates 28 that private market investors prioritize ESG practices as key driv- ers of long-term value creation and risk mitigation. The private market asset class continues advancing ESG implementation, given its structural advantages and increasing LP demand for responsible investing approaches. ESG value proposition in private markets Private markets offer unique advantages for ESG implementa - tion and value creation. The long-term investment horizons, typically spanning 5-10 years, provide time and opportunity for significant ESG improvements. Investors in these markets often hold control positions, allowing them to directly influence company strategy and operations. This control, coupled with less public scrutiny compared to public markets, offers the flex - ibility to implement transformative changes. Private equity firms bring substantial operational expertise to their portfolio companies, which can drive tangible ESG changes. This hands-on approach enables the implementation of sustainable practices and the development of ESG-focused initiatives. Additionally, certain sectors within private markets, such as infrastructure, often have inherent ESG linkages. For example, renewable energy projects naturally align with environmental sustainability goals. By leveraging these structural advantages, private market investors are well-positioned to capitalize on ESG opportunities, potentially enhancing societal impact alongside financial returns.

• Conducting rigorous ESG due diligence to identify risks and value creation avenues • Setting and monitoring ESG KPIs for portfolio companies. • Implementing operational improvements to enhance sustainability and reduce costs • Developing new products and services aligned with sustainability trends • Providing detailed ESG reporting to limited partners Considering the case of TDR Capital's investment in Aggreko 29 , a global leader in temporary power solutions. TDR saw an op- portunity to leverage Aggreko's market position to drive the transition towards greener technologies in off-grid power gen - eration. Since acquiring the company in 2021, TDR has support- ed Aggreko in establishing new divisions focused on energy transition and hybrid technologies, with 70% of annual capex 30 now directed towards products supporting sustainability goals. While ESG integration is still evolving, we believe that private market investors view strong ESG practices as one of the key drivers of long-term value creation and risk mitigation. In our view, the private asset class is well-positioned to continue ad- vancing ESG implementation, given its structural advantages and increasing limited partner demand for responsible invest- ing approaches. As the sectors mature, we see great opportunity for private assets to become leaders in translating ESG considerations into tangible business improvements and financial returns. The ability to drive operational changes, coupled with longer investment horizons, allows private market investors to imple- ment meaningful ESG initiatives that can create lasting value. This positions the asset class uniquely to address global sus- tainability challenges while potentially enhancing investment performance. ESG integration in private markets and how it builds on a long ESG track record Over the past few years we have developed a comprehen- sive ESG screening and integration in our private market's strategies, that is built on our long-standing commitment to responsible investing. Our approach to ESG integration is built on four core ESG pillars; research and due diligence, engage- ment, exclusion and monitoring & reporting.

28) ESG data Convergency Initiative (EDCI) PWC EU Private Markets: ESG Reboot. 29) Reference to companies or other investments mentioned should not be construed as a recommendation to the investor to buy or sell the same but is included for the purpose of illustration. 30) Source: TDR Capital December 2024.

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