SFDR Disclosure

Introduction

The following statement is provided by MVI Advisors AB, Reg. No. 559094-8864 on behalf of itself and its various subsidiaries and associated entities (“MVI”, we or us) pertaining to required disclosures under the Sustainable Finance Disclosure Regulation (“SFDR”).

MVI’s Pre-Investment Approach and the identification of Sustainability risks

For the purposes of SFDR, “sustainability risks” refer to an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Consideration of sustainability risks begin during the pre-investment assessment of any investment. We believe that active identification and appropriate management of sustainability risks are fundamental to operational excellence and risk management in the long-term of any business. Therefore, all investment opportunities that are reviewed by MVI pass through multiple assessments made by the investment team, industrial advisors, investment committee and external consultants, where sustainability risks, and other related financial and business risks and potential mitigators are identified, evaluated, and taken action on.

Investment opportunities are initially mapped to one of MVI’s investment themes and an investment thesis with a full-potential plan is formulated through discussions internally, with management and industrial advisors. As a part of the full-potential plan, initial sustainability risks, together with financial and other business risks, are identified and evaluated through internal research and analysis made by the investment team. All risks that are deemed to be potentially material for the investment case are highlighted with corresponding risk mitigators in the material that is prepared for the Investment Committee. Any investment opportunity that is deemed by the investment team or Investment Committee to inhibit unmanageable sustainability or business risks which cannot be mitigated are excluded prior to the initiation of external commercial, financial and legal due-diligence workstreams.

External commercial, financial and legal due-diligence workstreams are always initiated in the final stage of the pre-investment phase in order to confirm the investment thesis and full-potential plan. General sustainability risks and opportunities are always included in the scope of the workstreams, and potentially material risks already identified by the investment team and Investment Committee are independently followed up on and included in the scope of the due- diligence work-streams. If necessary, additional ESG due-diligence workstreams are initiated prior to a final investment recommendation being made to the Investment Committee.

Adverse sustainability impact statement

For the purposes of SFDR, “sustainability factors” refer to effects on environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

While MVI is committed to continue considering sustainability risks and opportunities in our investment process, we do not currently consider adverse impacts of investment decisions on sustainability factors as defined in the SFDR. We find it at present not feasible to conduct a reliable due diligence on the adverse sustainability impacts as defined in the SFDR and the proposed technical standards for SFDR level 2 given the size and investment strategies of our funds. Instead, guidance and resources are provided to our portfolio companies as deemed necessary during our active ownership period to help build and position the companies for long-term success in line with our investment thesis. By working in close partnership with our management teams and through participation on the boards of our portfolio companies, we assist our portfolio companies in adopting corporate governance procedures and identifying and managing environmental and social risks and opportunities.

MVI continues to evaluate and consider its obligations regarding the principal adverse sustainability impacts of investment decisions as set out in Article 4 and Article 7 (1) of SFDR. We await the completion of the technical standards for SFDR level 2, which is expected to enter into force in 2022. Decisions and publication in accordance with SFDR Articles 4 and 7 may be reviewed when the regulatory technical standards for SFDR level 2 have been adopted and when data and tools for measuring the adverse impacts on sustainability factors for unlisted small cap companies have been developed and become more efficient.