Policy for integration of sustainability risks

1.1. The Board of Directors of European Maritime Finance A/S (the “Company”) has adopted this policy for the integration of sustainability risks (the “Policy“), in order to establish a framework and guidelines for the Company’s work with sustainability in the investment process.

1.2. The company’s purpose is to facilitate investments in AIFs and create an attractive return in relation to risks for investors and support the green transition. This is based on a thorough investment analysis and process that includes the assessment of sustainability factors that may have a negative impact on investments.

2.1. The policy applies to all decisions, organizational levels and employees who are part of the investment process.

2.2. The policy is published via the Company’s website so that the investor can gain insight into how the Company integrates sustainability risks into the investment process, as well as how the Company continuously assesses sustainability risks that may have a negative impact on the value of an investment.

3.1. The company’s goal is to make investments in vessels with attractive risk-adjusted returns and support the green transition within the shipping industry, which is in line with the International Maritime Organization (IMO) goal of achieving zero emissions in the international shipping industry by 2050.

3.2. The sustainability strategy is organised according to environmental, social and governance factors (ESG – Environment, Social, Governance):

Environmental factors:

    • The company works to reduce the maritime industry’s emissions
    • The company invests in modern or newly built vessels, which have significantly lower environmental risks than older vessels and are prepared for green energy
    • The company prioritizes investing in vessels with advanced waste and ballast management systems


Social factors:

    • The company respects human rights
    • The company cooperates with maritime partners to ensure proper and satisfactory working conditions



    • The company complies with IMO’s maritime regulations, as well as international standards and conventions
    • The company has a high standard of transparency so that relevant stakeholders and investors are well informed about our investments
    • The company’s risk management is in line with and is an integral part of the investment process, which must identify and address potential risks in order to create robust investments

4.1. The company’s overall ESG objective is to support the IMO objective of achieving net zero CO2 emissions from international shipping around or close to 2050. In this context, the company also has the following objectives compared to 2008:

  • 2030 at least 20% striving for 30% compared to 2008
  • 2040 at least 70%, aiming for 80% compared to 2008


4.2. The EU Disclosure Regulation (SFDR) means that the Company is subject to EU legislation regarding the management of sustainability risks. Furthermore, the Company must comply with associated disclosure requirements regarding the degree of sustainability of the investment products.

The company’s website must state:

  • Policies for sustainability risk integration
  • How the company lives up to responsible business practice
  • How the company takes into account negative sustainability factors
  • How sustainability issues are included in wage policy


4.3. Categorisation of sustainability is done in accordance with the Disclosure Regulation:

  • Article 9 products: AIFs aiming at sustainability investments.
  • Article 8 products: AIFs promoting sustainability characteristics.
  • Article 6 products: AIFs that do not aim to promote sustainability characteristics.


4.4. The company is a signatory to the UN Principles for Responsible Investment and has committed the company to living up to environmental, social, and behavioural principles in our decisions and investments. 

The 6 principles are as follows:

  • Principle 1: ESG is integrated into investment research and decision-making processes
  • Principle 2: Incorporation of ESG into policies and practices
  • Principle 3: Disclosure of ESG matters on investments made
  • Principle 4: Contributes to the dissemination of the principles in the investment sector
  • Principle 5: Contributes to increased efficiency in implementing the principles
  • Principle 6: Reporting on the implementation principles

5.1. The company is continuously working to identify sustainability risks that could have a negative impact on the return of an AIF. The company identifies and prioritises potential sustainability issues and risks for each respective investment case. This is done based on the circumstances in question, the specific investment case and the data basis available to the company.

6.1. The company integrates sustainability risks into all investment projects and investment decisions of the AIFs. The company is tries, and where possible, reduces sustainability risks to protect AIFs’ returns.

6.2. Demands are placed on partners and their ability to handle sustainability risks.

6.3. For Article 8 AIFs, the company will:

  • assess and integrate ESG issues into the investment process from decision to market analysis, acquisition, ownership, operation, and divestment.
  • When selecting collaborators, assess their abilities to handle ESG issues in a satisfactory manner.
  • update and act in accordance with sustainability regulation, including by reporting on ESG on an ongoing basis.
  • monitor climate change, so that investment projects are designed to make assets resilient to possible climate regulatory changes.

7.1. It is the responsibility of the Executive Board:

  • that this policy is complied with and communicated to the Company’s employees, directors, and members of any investment committee;
  • to ensure that an annual review is carried out to assess the adequacy and effectiveness of the policy; and
  • to ensure that any deficiencies in the Policy or non-compliance with the Policy by relevant employees are reported to the Board of Directors for correction of the Policy.

8.1. The Board of Directors alone has the authority to approve changes to this­­ policy.

8.2. The Board of Directors may, from time to time, adopt, amend, revise or revoke this Policy or any portion thereof with respect to the Company’s investments as it deems appropriate in its sole discretion.

9.1. This Policy has been adopted at the Board meeting on January 24, 2024.

9.2. The policy will be reviewed annually to assess its proper functioning and any shortcomings will be addressed.

No Consideration of Sustainability Adverse Impacts

This disclosure is based on the provisions set out in Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability reporting in the financial services sector, as supplemented by Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 specifying the content, methodologies and presentation of information in relation to sustainability indicators and adverse sustainability impacts, and the content and presentation of the information in relation to the promotion of environmental or social characteristics and sustainable investment objectives in pre-contractual documents, on websites and in periodic reports. (...)

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European Maritime Finance A/S


Kongens Nytorv 22,
1050 Copenhagen

+45 55 55 70 00

CVR 39635631


European Maritime Finance A/S has an AIFM (Alternative Investment Fund Managers) licence and is regulated by the Danish Financial Supervisory Authority.

REG 23327

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