Regulation (EU) 2019/2088, also known as the EU Sustainable Finance Disclosure Regulation (SFDR), requires, among other things, that investment fund managers disclose:
- how sustainability risks are integrated into investment decisions
- whether and how principal adverse impacts of investment decisions are considered
- how remuneration policies are consistent with the integration of sustainability risks in investment decisions
NMI is an investment manager registered with the Financial Supervisory Authority of Norway and is subject to the disclosure and reporting obligations set out in the SFDR. We have classified the five funds we currently manage as Article 9, so-called “dark green”.
Transparency of sustainability risk policies (Article 3)
Financial market participants shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision‐making process.
NMI invests in institutions providing financial inclusion to poor people in developing countries. We aim to create sustainable long-term impact with our investments while providing attractive returns to our investors. We believe the best way to create sustainable long-term impact is by helping to develop well-managed, financially healthy, scalable financial institutions.
We prefer to invest in institutions that have a clearly stated social mission that describes the positive impact they aim to have on society. ESG and impact best practices are therefore fully integrated in our whole investment process, from the first assessment phase until we choose to exit the investment.
The responsibility for analysing and following-up on both the financial and the sustainability related risks in all phases of the investment process rests with the NMI investment professional responsible for each investment. The investment professional can, however, draw on the expertise of NMI’s specialised impact expert. For further details, please refer to our Social Performance Framework.
Consideration (or not) of principal adverse impacts of investment decisions on sustainability factors (Article 4)
Financial market participants shall publish and maintain on their websites:
(b) where they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons for why they do not do so, including, where relevant, information as to whether and when they intend to consider such adverse impacts.
NMI invests in institutions in developing countries with the aim of creating sustainable long-term impact. Assessments of possible adverse sustainability impacts are an integrated part of our investment process. NMI has an exclusion list aligned with best practice in the financial inclusion industry, which is based on both the association of European Development Finance Institutions (EDFI) and International Finance Corporation (IFC) general exclusion lists.
NMI currently does not consider the principal adverse sustainability impact indicators (PASI) as defined by SFDR. It is our view that it is still not possible to obtain sufficient data of a strong enough quality for all our investments to report on the stipulated indicators in Table 1 of Annex 1 of the draft Regulatory Technical Standards supplementing Article 4 of the SFDR. This must be understood both in the context of the maturity of the companies we invest in and the challenging environment in which they operate. We will review our readiness to comply annually and revise our position when the availability of relevant data increases.
Remuneration policy consistent with the integration of sustainability risks (Article 5)
1. Financial market participants and financial advisers shall include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks and shall publish that information on their websites.
NMI’s remuneration policy is consistent with the integration of sustainability risks. We reward our employees based on merits and talent and aims to offer competitive, albeit not market-leading, compensation. None of NMI’s staff are entitled to variable remuneration (no bonuses), and NMI’s investors are only charged a fixed management fee, with no carried interest. The remuneration packages are evaluated annually.