Introduction
Serendipity Partners Management AS (Serendipity Partners) is an alternative investment fund manager registered with the Financial Supervisory Authority of Norway. In accordance with Regulation (EU) 2019/2088 (SFDR), Serendipity Partners is required to disclose its policies for integrating sustainability risks into investment decisions, its remuneration policy, and whether it considers principal adverse impacts (PAI) of investment decisions.
Integration of Sustainability Risk in Investment Decisions
Serendipity Partners integrates sustainability risk into its investment decision-making process for funds under management. Sustainability risk refers to environmental, social, or governance-related events or conditions that may have an actual or potential material negative impact on the value of an investment.
Sustainability risks may arise from investments made by Serendipity Partners or from external factors that could affect future returns. The company recognizes that adverse sustainability impacts can reduce risk-adjusted returns and may materialize at any stage of the investment lifecycle.
Serendipity Partners manages funds primarily investing in healthcare companies in Europe, with a focus on the Nordics. Investments in companies with poor sustainability performance may expose the funds to reputational, regulatory, and financial risks, potentially impacting returns. The company seeks to identify and assess sustainability risks, including those related to climate change, human rights, corruption, governance standards, healthcare compliance, supply chain issues, and ethical considerations in clinical trials.
Measures to Mitigate Sustainability Risks
Depending on the investment opportunity, Serendipity Partners may implement the following measures to mitigate sustainability risks, both before investment and during the holding period:
- Conduct due diligence on company- and industry-specific sustainability risks
- Integrate ESG factors into risk management and decision-making
- Engage with investee companies to address sustainability risks and promote ESG best practices
- Monitor and report on ESG performance
- Support the development and implementation of ESG action plans
- Utilize external ESG expertise and resources
Principal Adverse Impacts (PAI)
Currently, Serendipity Partners does not consider principal adverse impacts (PAI) of investment decisions on sustainability factors at the fund level, in accordance with Article 4 of SFDR.
This is due to, inter alia, the following reasons:
- Data Availability and Quality: For many of our investments there is still limited access to standardized and reliable ESG data necessary to assess and report on the PAI indicators as outlined in the SFDR Regulatory Technical Standards (RTS). It is important to note that many of the companies and projects in which we invest do not have clear obligations to disclose the necessary information for such evaluations
- Proportionality and Resource Allocation: As a small to medium-sized manager, we aim to ensure that our approach to sustainability integration is proportionate to our resources and the needs of our clients. We are therefore continuously assessing when and how it may be appropriate to implement full PAI reporting at the product level.
We will continuously evaluate whether, and if so when, we will begin to consider PAIs in our funds. This will depend, among other factors, on developments in data availability, regulatory clarification, and investor expectations. Any changes to our approach will be published on this site and included in future updates to our fund and sustainability documentation.
Funds managed by Serendipity Partners:
As of 5 January 2026, Serendipity Partners manages the AIFs Serendipity Partners Fund AS and Serendipity Topro Co-Invest Fund AS. Both are classified as mainstream funds under SFDR Article 6, meaning they do not have a sustainable investment objective (Article 9) and do not promote environmental or social characteristics (Article 8). The funds are not required to make sustainable investments under SFDR Article 2(17).
Taxonomy Regulation Statement
In accordance with Article 7 of the Taxonomy Regulation:
The underlying investments of the funds do not take into consideration the EU criteria for environmentally sustainable economic activities.
Information on remuneration policies
In accordance with Article 5 of SFDR, Serendipity Partners shall include information in their remuneration policies information on how those policies are consistent with the integration of sustainability risks.
The remuneration policy is consistent with the integration of sustainability risks. Remuneration does not contain variable components and, as such, no incentives for excessive risk-taking, including sustainability risks, that could encourage decisions that could result in material adverse impacts on the long-term value of the funds managed. Remuneration is balanced to promote sound and effective risk management aligned with the firm’s overall risk profile.
Transparency in pre-contractual disclosures
Where required by SFDR, all managed funds must include relevant descriptions in pre-contractual disclosures (e.g., Private Offering Memorandums, prospectuses, or Article 23 AIFMD disclosures) detailing how sustainability risks are integrated into investment decisions and the likely impact on financial returns. If sustainability risks are not considered relevant, a clear explanation must be provided. Additionally, disclosures must state whether Principal Adverse Impacts (PAI) are considered, or provide reasons if they are not.