Environmental, 
Social and Governance 
Report 2022
We are decent people 
making a decent return 
in a decent way

FSN Capital ESG Report 2022
3
2
"We are decent people 
making a decent return 
in a decent way."
– FSN Capital Partners' Ethos
Chapter 1 
Introduction 
Chapter 2 
ESG integration throughout  
the investment lifecycle 
Chapter 3 
ESG developments in  
FSN Portfolio Companies 
Chapter 4 
Internal ESG initiatives 
and reporting 
Appendix
The ultimate goal of FSN Capital’s ESG work:  
Our ultimate ESG goal is to create Net Zero Sustainability Leaders 
with Good Governance & High Ethical Business Standards
14  
 
28 
50 
 
108 
 
122

FSN Capital ESG Report 2022
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As we look into the future, there are many unknowns, 
yet one thing is certain – we must face the brutal 
facts. As UN Chief António Guterres said at COP27 
in November 2022: “We are on a highway to climate 
hell with our foot still on the accelerator.” With this in 
mind, we must all have the courage to set bold targets 
and work steadfastly towards them. For us this is our 
Net Zero commitment. 
When I founded FSN Capital 24 years ago, I was 
committed to responsible investing, and built a firm 
with a strong and clear ethos leading the way: “We 
are decent people making a decent return in a decent 
way.” What constitutes responsible investing has 
changed over the years, and we have always done our 
part to drive the private equity industry forward in 
this regard. Now, responsible investing means being 
part of society’s necessary path to decarbonization, 
where we already have industry-leading goals with 
our Science Based Targets and Net Zero commitment 
(see fact box). We are humble to the fact that we have 
a big job in front of us to meet our decarbonization 
goals: emissions reduction will for many companies 
necessitate operational changes and cooperation across 
the full value chain.
We will continue to sharpen our tools to be able 
to best support FSN portfolio companies on their 
decarbonization path. We believe that one of our 
most valuable assets in an uncertain future will be our 
flexibility and openness to adapt, as we together search 
for the path to reach the bold goals we have set. One of 
our core values - growth mindset – is required for the 
journey ahead. 
The private equity industry is in a unique position 
to both capture the investment opportunity arising 
from the green transition and to increase the speed 
of the transition by accelerating the growth of such 
investments. FSN Capital will continue the race 
towards Net Zero by investing in companies that 
can contribute to reducing greenhouse gas (GHG) 
emissions in a material and quantifiable way, such as 
Obton and newly signed Polytech.
As always, we will do this with our Ultimate 
Clients in mind: the millions of workers, students, 
pensioners, and other citizens around the world, to 
whom we aim to deliver attractive investment returns 
in a responsible way.
This year’s report marks a milestone for our firm: 
for the 10th time we are transparently documenting 
how we choose to incorporate ESG into all stages 
of the investment process. As we work on meeting 
our bold goals, we will continue to report to our 
stakeholders on our progress, in the open and 
transparent manner we have strived for since 2013.
“We must all have the courage to set 
bold targets and work steadfastly 
towards them. For us this is our  
Net Zero commitment.”
Letter from our Chairperson
– The courage to set bold targets 
Frode Strand-Nielsen, 
Founder, Chairperson, and Partner responsible for ESG at FSN Capital Partners
FSN Capital Partners has set clear 
and transparent GHG reduction 
targets verified by the Science 
Based Targets initiative
60%
Reduction in Scope 1 and 2 
emissions by 2026
100%
Share of portfolio companies 
to set SBTi targets by 2030

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Since inception, FSN Capital has been an industry 
leader in responsible investing. In an increasingly 
complex world, we believe our structured focus and 
commitment to ESG is proving ever more valuable.
When we look for companies to invest in, we 
always start by asking ourselves: “Will this company 
be relevant in the next decade or decades?” Applying a 
long-term perspective is not optional in our business, 
it is mandatory. With the green transition, increased 
stakeholders’ expectations on ESG, new and upcoming 
regulations, and employees’ preference to work for 
more sustainable companies, there is a clear link 
between a company’s ESG position or potential, and 
its future relevance and financial success. 
To generate returns for our Ultimate Clients  we 
have developed a standardised approach to value 
creation – our FSN Execution Framework (“FEF”, see 
p. 40). Our ESG approach is an integral part of FEF 
and therefore supports the commercial strategy of 
our portfolio companies. As a firm, we believe that to 
become a winner in any industry in the future, you 
must also be a sustainability leader. In the ownership 
period, we therefore utilise our industry-leading ESG 
frameworks to support portfolio companies in making 
the right priorities, acting fast, and driving change. 
Internally at FSN Capital, we continue to focus 
on our people. In 2022 we were finally able to go on a 
family offsite which had been postponed several times 
due to Covid-19. Meeting all the children and spouses 
of our employees and spending time together as a 
team was one of the absolute highlights of 2022! 
Building on several previous firm-wide diversity 
initiatives, we also launched a new diversity, equity, 
and inclusion (DEI) initiative in 2022. Throughout 
2023, our team will collaborate on topics including 
talent and recruitment, unconscious bias, and 
work-life balance. From this, we expect to create a DEI 
strategy that resonates with our ethos and values.
Outside of our firm, we have been pleased to see 
the increasing focus on ESG among our stakeholders. 
In 2022, we joined the World Economic Forum’s  
New Champions community, and we look forward to 
exchanging ideas and experiences with a community 
of future-focused companies that can enable us to 
together build a better and more sustainable future. 
Robin Mürer and Ulrik Smith 
Co-Managing Partners 
FSN Capital Partners 
Letter from our  
Co-Managing Partners
– The structure to execute change 
“To become a winner in any 
industry in the future, you must 
also be a sustainability leader.”

FSN Capital ESG Report 2022
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FSN Capital at a Glance 
FSN CAPITAL OFFICES
➊  Oslo, Est. 1999
➋  Stockholm, Est. 2006
➌  Copenhagen, Est. 2010
➍  Munich, Est. 2017
➊
➋
➍
0.25 bn
0.50 bn
0.75 bn
1.00 bn
1.25 bn
1.50 bn
1.75 bn
2.00 bn
0
2000
Fund I
54 m
151 m
380 m
610 m
1.0 bn
1.8 bn
2005
Fund II
2020
Fund VI
2016
Fund V
2013 
Fund IV
2008
Fund III
QUICK FACTS - 20222
FUNDS RAISED (EUR)
1.	
As of March 2023
2.	 Numbers updated as of 31.12.22, excludes holdings in listed companies
3.	
Past performance is not necessarily indicative or a guarantee of future results
25
Active portfolio companies
24%
2022 revenue increase in  
FSN portfolio companies,  
22% increase in 20213
200+
Add-ons advised by FSN Capital
37%
2022 EBITDA increase in  
FSN portfolio companies,  
26% increase in 20213
~128
Total countries FSN portfolio 
companies operate in
19 891
people employed by FSN  
portfolio companies (FTEs),
48% increase from 2021
➌
Established in 1999, FSN Capital Partners (FSN Capital) is a leading Northern European private equity firm and 
investment advisor to the FSN Capital Funds (FSN Funds), with €4 billion assets under management. FSN Funds 
make control investments in growth-oriented Northern European companies, to seek to support further growth 
and to transform companies into more sustainable, competitive, international, and profitable entities. FSN 
Capital has a team of more than 80 professionals across Oslo, Stockholm, Copenhagen, and Munich, in addition 
to 13 executive advisors with extensive industry experience1.
Learn more about FSN Capital on: www.fsncapital.com

FSN Capital ESG Report 2022
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Our Ultimate Clients
PENSIONERS
STUDENTS
FAMILIES
RESEARCHERS
PUBLIC EMPLOYEES
Our purpose is to contribute to the welfare of everyday people.
We serve our investors, whose underlying beneficiaries constitute 
millions of pensioners, workers, students, and other citizens around 
the world who trust FSN Funds with their money. These are our 
Ultimate Clients.
We believe that our Ultimate Clients are best served when we create 
returns in a decent way - with focus on sustainable growth for the 
benefit of both our investors and society at large.

FSN Capital ESG Report 2022
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Creating Welfare for 
our Ultimate Clients
Building Lasting Growth
WEALTH CREATED DURING OWNERSHIP PERIOD
NOK (bn)
Total net wealth 
created
Source: McKinsey
1.	
OMX Nordic All-Share average
Indices and other market comparisons are included to show general market trends during the period indicated and are not 
intended to imply that any FSN Fund’s portfolio or any individual portfolio company is similar to the companies included in the 
relevant index or market comparison in either composition or risk. The investment characteristics and risk/return profile of an 
index differ materially from any FSN Fund, and it should not be assumed that correlations with any index based on historical 
returns will continue.
26
Market wealth 
created
Incremental wealth 
created
WEALTH CREATED POST OWNERSHIP PERIOD
8.5
17.5
100
150
200
250
300
350
400
450
500
Share price
(Index 100 = share price at IPO)
FSN portfolio companies
Index1
50
+1
Year
+2
Years
+3
Years
FSN IPO’s 
generating 
~NOK 29.4bn 
return above 
market 
returns
287
143
(L3Y share price performance)
(+163%)
(+359%)
(+277%)
(-38%)
(+213%)
(+147%)

CHAPTER 1 — Introduction
FSN Capital ESG Report 2022
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Introduction 
How we think about ESG at FSN Capital, 
what we have accomplished in 2022, and 
our plans for 2023
CHAPTER 1

CHAPTER 1 — Introduction
FSN Capital ESG Report 2022
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We Take Part in 
Leading the Way
We were early movers and among the first private 
equity firms in the world to (i) set Science Based 
Targets and make Net Zero Commitments in 2021, 
and (ii) put in place a sustainability-linked financing 
facility in 2020 (see more info on p. 18 & 120). We are 
dedicated to maintaining our position as an industry 
leader in responsible investing. However, the change 
that needs to happen for the world to move towards 
a more sustainable society is of overwhelming scale 
and complexity. Collaboration across industries, value 
chains, and among peers will be a key success factor 
for solving the challenges ahead. We are grateful for 
our cooperation with peers through the Initiative 
Climat International (iCI), which we see as a catalyst 
for change.
Given our historically strong focus on ESG as 
a firm, our bold ESG targets, and our robust ESG 
Frameworks, we are in a unique position to drive 
change and capture the commercial value of ESG. This 
will help us realise our purpose of contributing to the 
welfare of everyday people, by creating a decent return 
in a decent way.
Our ultimate ESG goal is to create Net Zero 
Sustainability Leaders with Good Governance 
& High Ethical Business Standards
FSN’S PORTFOLIO COMPANY TARGETS
 FSN’S ESG FRAMEWORKS 
Mia Sørli Wikborg
ESG Associate
Katti Frølich
ESG Intern
Jeanette Fangel Løgstrup 
Senior ESG Advisor
Rebecca Christine Svensøy
General Counsel and Head 
of ESG
FSN CAPITAL’S ESG TEAM
 100%
All FSN portfolio 
companies create own 
ESG strategy
ESG Strategy 
Framework
100%
All FSN portfolio 
companies adopt & 
implement 
ESG policies with 
clear governance
Governance 
Framework 
ESG in sourcing and due diligence 
100%
All FSN portfolio 
companies to set 
Science Based 
Targets
Climate Framework
100% 
All FSN portfolio 
companies to have at 
least one female board 
member*
Diversity
At FSN Capital, the commercial value of our ESG 
work is strongly anchored at the top with our partner 
group and in our ethos. Not only do we all agree that 
the growth we seek in FSN portfolio companies, 
to ensure return to our Ultimate Clients, needs to 
be sustainable – we also believe that a robust ESG 
focus will be a competitive advantage for portfolio 
companies going forward.
To ensure that FSN portfolio companies remain 
resilient and relevant in the future, our ultimate ESG 
goal is to create Net Zero sustainability leaders with 
good governance and high ethical standards - for the 
benefit of both our investors and society at large.
All FSN portfolio companies must apply the three 
FSN ESG Frameworks - no exceptions (please see 
Chapter 2 for details on our three ESG frameworks). 
We in the ESG team have the pleasure to work closely 
with all portfolio company management teams to 
ensure deep ESG integration. Our contribution is  
to take part in shaping the sustainability leaders  
of tomorrow.
*Female board members to total board members (excludes FSN Capital employees, minority shareholders, and employee representatives)

CHAPTER 1 — Introduction
FSN Capital ESG Report 2022
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FSN’S DIVERSITY INITIATIVE
(see p. 112 for more details) 
For a full overview on Fund VI portfolio companies' performance against the ESG KPIs, see p. 120
FSN’S CLIMATE FRAMEWORK
(see p. 42 for more details) 
FSN’S ESG STRATEGY AND GOVERNANCE FRAMEWORK
 (see p. 34 and 38-41 for more details)
Sustainability-Linked 
Subscription Facility
FSN Capital Fund VI has a sustainability-linked subscription facility, 
designed to further incentivise implementation of FSN's ESG 
Frameworks in portfolio companies. Under this facility, interest rate 
is determined by 3 ESG-related KPIs.
KPI 2: GREENHOUSE GAS EMISSIONS
A.
GHG REPORTING SYSTEM
Each FSN portfolio company set up online GHG reporting system
B.
GHG EMISSIONS SCOPE 1 & 2
Each FSN portfolio company report Scope 1 and 2 emissions
C.
GHG EMISSIONS SCOPE 3
Each FSN portfolio company report Scope 3 to the extent deemed relevant
D.
GHG EMISSIONS TARGET
Each FSN portfolio company set ambitious GHG reduction target
KPI 3: DIVERSITY RATIO
A.
GENDER DIVERSITY RATIO
Incentive for having more than 25% female portfolio 
company board members*. Interest margin increases if this 
indicator falls below 20% (in aggregate)
*Female board members to total board members (excludes minority shareholders, FSN Capital employees, and employee representatives)
KPI 1: ESG STRATEGY AND GOVERNANCE
A.
ESG STRATEGY AND CLIMATE ASSESSMENT
Each FSN portfolio company shall develop an ESG strategy with 
annual targets
B.
ESG OWNERSHIP
Designate political (board) and operational (management) 
ownership per FSN portfolio company
C.
ESG BOARD MEETING STATUS REPORT
Confirmation that ESG has been discussed semi-annually by the 
board of directors in each  portfolio company
Emissions (tCO2e)
1.5°C-aligned
emissions pathway
Short term target
Long term target
Net-zero emissions
Raw material 
supply
Production
Management & 
marketing
Customers & 
end-users
 
COMPANY
Employees
Regulators
Investors
Megatrends
Customers
Climate
Competitors
Suppliers
Interest
Groups

Emissions (tCO2e)
1.5°C-aligned
emissions pathway
Short term target
Long term target
Net-zero emissions
CHAPTER 1 — Introduction
FSN Capital ESG Report 2022
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2019
	·
Introduced the FSN Climate Framework, 
based on recommendations from the 
Task Force on Climate-Related Financial 
Disclosures (TCFD)
	·
Rolled out our climate change due 
diligence approach
	·
Sustainability-linked subscription 
facility launched
	·
Joined Initiative Climat International 
(iCI)
	·
Committed to Science Based Targets 
and Net Zero
	·
Integrated double materiality into the 
FSN ESG Strategy Framework
2020
2022
2021
	·
Introduced Principal Adverse Impact 
(PAI) and EU Taxonomy screening 
in investment process and of certain 
FSN portfolio companies
	·
Started portfolio company Science 
Based Target journey through FSN’s 
Decarbonization Module
	·
Became signatory of the Principles 
for Responsible Investment (PRI)
	·
Introduced the FSN ESG Strategy Framework, 
based on elements of the EU Non-financial 
Reporting Directive (NFRD), supporting all FSN 
portfolio companies in developing tailormade ESG 
strategies
Raw material 
supply
Production
Management & 
marketing
Customers & 
end-users
 
2012
2014
Our Strong Historic Focus on ESG
ESG has been a core part of FSN Capital's DNA and value creation 
approach since the inception of the firm.
As a firm we see ourselves as a learning organisation with 
continuous improvement processes in everything we do, including 
our ESG approach. We continue to push the frontier when it comes 
to what it means to be a responsible owner.  
	·
Conducted the first stakeholder 
assessment and published the first 
ESG report (for FY 2013)
BUILDING LASTING VALUE
FSN Capital
Environmental, Social and Governance report 2013
Building Resilient Companies
BUILDING RESILIENT COMPANIES
FSN Capital
Environmental, Social and Governance report 2018
Building Resilient Companies
BUILDING RESILIENT COMPANIES
FSN Capital
Environmental, Social and Governance report 2017
Building Resilient Companies
2017

FSN Capital ESG Report 2022
CHAPTER 1 — Introduction
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Playing our Part
At FSN we aim to use our ownership position to drive positive change. We believe that we 
can further scale our contribution by mobilising and cooperating with other too. 
In addition, international ESG frameworks have influenced what we view as material ESG 
topics and how we work with these topics. Please see page 118 for more information on how 
we work with the UN Principles for Responsible Investment (PRI) and the Sustainable 
Development Goals (SDGs) in practise. 
COMMITTED TO:
INCORPORATED ESG FRAMEWORKS:
HISTORICAL PRI SCORECARD 
2014
2015
2016
2017
2018
2019
2020
2021
Strategy & Governance*
C(B)
B(B)
B(B)
B(A)
A(A)
A(A)
A+(A)
94/1001 
★ ★ ★ ★ ★
Private Equity*
B(B)
A(B)
A(B)
A+(B)
A+(B)
A+(B)
A(A)2
99/100 
★ ★ ★ ★ ★
*Scores in parenthesis refers to the median peer score 
1. 	 In 2021 PRI used another methodology referring to Investment & Stewardship Policy rather than Strategy & Governance 
2. 	 Due to a reporting error on the existence of our responsible investment policy we were awarded an A rather than a A+ in 2020
CSDDD

CHAPTER 1 — Introduction
FSN Capital ESG Report 2022
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Industry awards
	·
FSN Capital named as Real Deals’ Future 40:  
ESG Innovators 2022
	·
FSN Capital received "the Green Prize Award 
2022" at Aktive Ejere - Active Owners Denmark, 
the Danish PE/VC association's annual summit
	·
FSN Capital shortlisted for the ”ESG – Mid Cap” 
category at Real Deals ESG Awards 2022
Select speaker events
	·
Knut Kjær, Partner, spoke about “Sustainable 
Finance” at the Norwegian Society of Financial 
Analysts' (NFF) Seminar in Oslo, and “How 
Assets owners can contribute to the Green energy 
transition” at Responsible Asset Owners APAC
	·
Frode Strand-Nielsen, Founder and Chairperson, 
participated in Wikborg Rein’s asset management 
seminar and called for a plan to make Norway 
a world leader in investments to fuel the green 
transition
	·
FSN Capital hosted an ESG breakfast seminar 
together with Frank Partners
	·
FSN Capital hosted a lecture at Stockholm School 
of Economics on how we incorporate ESG across 
the investment process
Participation in the public debate has made FSN Capital known for 
its values and ESG focus. 2022 was another successful year for FSN 
Capital when it comes to advocating for the effectiveness of ESG. 
We also received international recognition through several industry 
ESG awards.
ESG Awards & Events
Awais Shafique, FEF Director and 
Marcus Wintersø, Investment 
Director, receiving “the Green prize 
Award 2022” in Copenhagen
Justin Kent, Partner, speaking at  
FSN Capital and FP’s ESG breakfast 
seminar
Frode Strand-Nielsen, Founder and 
Chaiperson, at Wikborg Rein’s asset 
management seminar
Mike Joseph, Investment Associate, 
and Mia Sørli Wikborg,  
ESG Associate, speaking at  
Stockholm School of Economics

CHAPTER 1 — Introduction
FSN Capital ESG Report 2022
Start Nordic chapter of Initiative Climate 
International (iCI)
The planned organisational structure of iCI was changed during 
2022. There will be one European chapter rather than many 
regional chapters going forward
Develop a standard approach for setting and 
achieving Science Based Targets (SBTs)
By further refining the Decarbonization Module in FSN’s 
Climate Framework we have supported FSN portfolio companies 
in preparing for and setting SBTs  
Continue EU taxonomy analysis of portfolio 
companies
Utilised a new semi-automated digital tool to high-level assess 
EU taxonomy* eligibility for prospective and current FSN 
portfolio companies
Update standard ESG policies and whistle-
blower policy overview per jurisdiction 
Updated FSN’s standard policies to reflect recent changes in 
applicable laws and best practices in all core jurisdictions
Create and share a step-by-step plan for best 
practice supply chain management
Created a third-party risk management procedure to support 
FSN portfolio companies’ supply chain management, and a 
guidebook to assist companies in meeting the legal requirements 
under Norway’s new Transparency Act (Åpenhetsloven)
Present at two ESG seminars in the  
DACH region
Held one ESG webinar in the DACH region
~
~
26
27
Delivering on our Commitments
WHAT WE SAID WE WOULD DO IN 2022
HOW WE DID IT
Each year we create a list of key new ESG efforts that we aim to 
pursue in the coming year. To keep ourselves accountable we 
disclose publicly how we are doing on those commitments.
WHAT WE WILL AIM TO DO IN 2023
	·
Hire additional full-time dedicated resource to the FSN Capital ESG team to further support portfolio 
companies on their journey to Net Zero
	·
Further strengthening the link between ESG and incentives for FSN Capital employees, and develop 
standard templates and process for inclusion of ESG metrics in FSN portfolio companies' executive 
incentive plans
	·
Collaborate with our peers through iCI with a focus on Net Zero
	·
Work with FSN portfolio companies to ensure that they have detailed action plans with specific steps, 
timelines and responsibilities, to deliver on their ESG strategies, emission reduction, and policies 
implementation plans
	·
Provide supply chain management training to FSN portfolio companies to further enhance focus on 
human rights
	·
Consider how to further incorporate biodiversity and nature at the due diligence stage and in strategy 
discussions with FSN portfolio companies
*FSN Capital makes no commitment to achieving Taxonomy-alignment for any FSN portfolio companies

CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
FSN Capital ESG Report 2022
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Our standard ESG frameworks for value creation, 
applied across all investments
ESG Integration 
Throughout 
the Investment 
Lifecycle
CHAPTER 2

CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
FSN Capital ESG Report 2022
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Exit
 
OWNERSHIP PERIOD  
To ensure portfolio companies meet FSN’s expectations 
and ambitions in respect of ESG, we have developed a 
standard onboarding program and frameworks for value 
creation.
In the onboarding meetings, the FSN Capital ESG 
team introduces portfolio company management and 
the board to the following ESG priorities:
1.	 Assign an ESG Officer to lead execution of the three 
FSN ESG frameworks;
2.	 Adopt and create a plan for implementation of FSN’s 
standard ESG policies (per the FSN Governance 
Framework on p. 38);
3.	 Develop an ESG strategy and action plan (per the 
FSN ESG Strategy Framework on p. 40); and
4.	 Map, report and set reduction targets for GHG 
emissions (per the FSN Climate Framework on p. 42).
We seek to build companies that remain 
sustainable after our ownership period. Accordingly, 
our ESG approach is focused on integrating key ESG 
topics into the strategy, operations, and culture of each 
portfolio company.
We aim to drive lasting change by combining our 
standardised ESG approach with establishing personal 
relationships with management teams. Together we 
emphasise continuous improvement and “positive 
dissatisfaction,” building cultures that challenge the 
status quo.
By the time we exit our investment, our ambition is 
for sound ESG management to have reduced risks and 
positioned the company as a sustainability leader in its 
industry, thereby increasing the value of the company.
Exit 
Resilient and sustainable 
companies  
Onboarding 
Align on  
material ESG 
 topics & create  
execution plan 
Ownership period 
Support position as  
sustainability leader,  
monitor and report 
FSN Capital applies a long-term perspective and integrates material 
ESG considerations in all stages of the investment process, from 
sourcing through to exit.
PRE-INVESTMENT
Our target is high-quality companies operating 
in Northern Europe with the potential to double 
EBITDA through sustainable growth and with limited 
exposure to uncontrollable beta risks.
Our guiding star is our ethos and our values, 
captured in FSN’s Responsible Investment Policy 
and its clear exclusion criteria (see p. 33 & 125).
In the early screening phase, we conduct a  
climate change due diligence and assess potential 
investments’ impact on the world, as well as potential 
eligibility under the EU taxonomy. Our early-stage 
ESG screening supports our teams to identify 
companies well-positioned to capitalise on emerging 
trends, while seeking to avoid companies with 
exposure to clear transition or physical climate risks 
(see p. 32).
When the transaction moves one step further, we 
apply our standard ESG due diligence approach.
We aim to identify how to support potential 
investments in becoming sustainability leaders in 
their respective industries by analysing material ESG 
topics and how to address these, focusing on both 
opportunities and risks. Further, in our race to Net 
Zero, we identify the material sources of a company's 
GHG emissions and potential measures to reduce 
these. We always conduct an integrity due diligence 
of key stakeholders (see p. 34).
Information from the early-stage screening 
and ESG due diligence is a mandatory part of the 
investment decision material. ESG is also included 
in the risk framework (see p. 36).
Sourcing &  
early-stage screening 
Consider ESG 
impact
Investment decision 
Mandatory ESG 
 summary 
Overview of FSN’s 
ESG Approach
Due Diligence 
Identify material  
ESG topics and  
high level path  
to Net Zero

Early-stage screening
CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
FSN Capital ESG Report 2022
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33
FSN’s Responsible Investment Policy 
Defines our formal exclusion criteria, stating that we shall not invest in 
companies that: 
Net Impact & SDG 
alignment assessment
At FSN we want to understand the social and environ-
mental impact of the companies we consider to invest 
in. We also want to understand to what extent a 
company's activities are aligned or misaligned with 
the SDGs.
In 2022 we therefore started screening for both net 
impact and SDG alignment at the early-stage screening 
phase. We use a software that semi- automatically 
quantifies companies’ net impact on people, planet, 
society and knowledge. The output from this initial 
screening further informs the scope of the ESG and/or 
commercial due diligence.  
EU Taxonomy & Principal 
Adverse Impact screening
In 2022 we started using a software that in a semi- 
automated way conducts a high-level screening of EU 
Taxonomy eligibility and Principal Adverse Impact 
indicators early in the investment phase for every 
potential investment.
What we have learned is that most companies do 
not have relevant data available as of now. If we make 
the investment, we aim to work with the portfolio 
company on a more detailed assessment, and on a plan 
to gather relevant data for each applicable KPI.   
External experts have also conducted a high-level 
EU Taxonomy screening of current portfolio 
companies. Details on each FSN portfolio company 
can be found in their ESG strategy in Chapter 3.
Early-Stage ESG Screening
Climate Change Due Diligence
PURPOSE: IDENTIFY CLIMATE RISKS AND OPPORTUNITIES
A standard requirement in all our transactions is that 
the deal team conducts a high-level climate change 
due diligence early in the investment phase. A more 
detailed analysis will be conducted later in the process 
by external experts as part of the ESG due diligence. 
The climate change due diligence approach 
was developed by FSN’s ESG team in 2019 inspired 
by the Taskforce on Climate-related Financial 
Disclosures (TCFD). We have developed the due 
diligence tool, templates, and a mandatory training 
video. Our training video goes through the below 
four-step process.
Value chain 
mapping
Transition risk  
and opportunity  
assessment
Physical risk 
and opportunity  
assessment
Conclusion and 
summary in 
investment 
proposal
PHYSICAL RISKS AND OPPORTUNITIES
Location-based assessment of 
physical risks as companies in the 
same jurisdictions are exposed to 
similar:
	·
Climate and temperature change
	·
Acute weather events
TRANSITION RISKS AND OPPORTUNITIES
Sector-based assessment of 
transition risks as companies in the 
same sector share similar:
	·
Industry standards
	·
Technology
	·
Markets and customers
	·
Regulatory 
	·
Have contributed to systematic denial of 
human rights
	·
Demonstrate a pattern of non-compliance with 
environmental regulations
	·
Show a pattern of engaging in child labour or 
forced labour
	·
Have an unacceptable high greenhouse gas 
footprint and have failed to take reasonable 
steps to reduce these emissions
	·
Produce weapons that through their normal 
use may violate fundamental humanitarian 
principles (e.g. antipersonnel landmines, 
production of cluster munitions, production of 
nuclear arms)
	·
Are directly related to adult entertainment, 
tobacco, gambling or alcohol
FSN’s Responsible Investment Policy is included as 
appendix on p. 124

Due Diligence
CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
FSN Capital ESG Report 2022
34
35
As part of FSN Capital’s Science Based Targets, we 
have committed to support our portfolio companies 
in setting their own Science Based Targets with the 
goal to drive FSN’s portfolio to Net Zero. We therefore 
want to understand already in the due diligence phase 
how a potential investment’s GHG emissions can be 
reduced during our ownership period.     
Our approach on this has gradually evolved during 
2022, and from Q2 2023 we will in every transaction 
complete a high-level outside-in assessment of:
	·
the most material sources of GHG emissions in the 
company’s value chain 
	·
how to reduce the most material GHG sources 
	·
level of effort and costs of reaching Net Zero
	·
the commercial value of Net Zero initiatives 
Net Zero
PURPOSE: UNDERSTAND HOW 
POTENTIAL INVESTMENTS CAN 
BECOME NET ZERO
We believe that culture is the key ingredient in driving 
the ESG agenda. We therefore have external experts 
conduct an integrity due diligence of the company, its 
board and management, and seller(s) to ensure they 
share our values. 
Integrity
PURPOSE: ENSURE KEY STAKE-
HOLDERS SHARE OUR VALUES
Emissions (tCO2e)
1.5°C-aligned
emissions pathway
Short term target
Long term target
Net-zero emissions
The ESG Due Diligence
ESG Materiality & Gap Analysis
PURPOSE: UNDERSTAND HOW POTENTIAL INVESTMENTS 
CAN BECOME SUSTAINABILITY LEADERS IN THEIR INDUSTRY 
An ESG due diligence conducted by internal and 
external experts is a standard requirement for all new 
potential investments. Material ESG information is a 
mandatory part of the investment decision material.
We will from Q2 2023 update our standard ESG 
due diligence approach to include a double materiality 
assessment.
Double materiality means that we assess both the 
company’s impact on the world through its full value 
chain, and the impact of the world on the company, 
covering all material stakeholders and climate 
scenarios analysis (see p. 42 for more details). We use 
primary information from the company, expert inter-
views, and industry standards and frameworks as input 
sources to the analysis. 
Once the material ESG topics are identified through 
the double materiality analysis, a gap and maturity 
assessment provides the basis for recommendations by 
the external experts on how to meet best practice in 
the ownership period. This forms our understanding of 
how this company can become a sustainability leader in 
its industry. 
When it comes to ESG risks, our ESG due diligence 
approach includes an assessment of the company’s 
inherent ESG risks based on industry, jurisdictions, 
suppliers, and customers, and how the company is 
currently addressing these risks. The external ESG 
experts will advise on the company’s residual ESG 
risk profile and provide recommendations on how to 
improve during the ownership period.
COMPANY’S IMPACT ON THE WORLD
WORLD’S IMPACT ON THE COMPANY
Raw material 
supply
Production
Management & 
marketing
Customers & 
end-users
 
COMPANY
Employees
Regulators
Investors
Megatrends
Customers
Climate
Competitors
Suppliers
Interest
Groups

Investment Decision
FSN Capital ESG Report 2022
CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
36
37
Investment Decision
Risk Framework
 
FSN’s Risk Framework is used for detailed analysis of alpha and beta risks in a due diligence 
process. Alpha risks are risks that we can seek to manage actively by our guidance, while beta 
risks are beyond our control.
The early-stage screening and ESG due diligence supports the deal teams in investing 
in the right companies: it uncovers potential ESG risks and identifies commercial ESG 
opportunities.
Information from both the early-stage screening and the ESG due diligence forms a 
mandatory part of the investment decision material and is also used as input for the scoring 
of ESG risks in FSN’s Risk Framework.
Macro
	·
Cyclicality *
	·
FX *
	·
Commodity *
Industry
	·
Political *
	·
Competitiveness
	·
Substitution
Commercial
	·
Operating leverage
	·
Concentration
	·
Visibility
Weather *
Operational
	·
Management risk
	·
Integration risk
	·
Internal / External
Financial
	·
Liquidity
	·
Leverage
	·
Covenants
Exit
	·
Multiple  
sustainability *
	·
Marketability *
	·
Dependency on 
trend shift
Active ownership
	·
Majority shareholder
	·
Ultimate control
Environmental
	·
Toxic emissions
	·
Harmful industrial waste
	·
Deforestation
Social **
	·
Labour conditions
	·
Forced / Child labour
	·
Harm to health and safety
Governance
	·
Bribery / Fraud
	·
Political interference *
	·
Criminal convictions
	·
Regulatory relations
*	
Beta risk
**	 Where these risks occur throughout the value chain, they are more likely to constitute beta risks

Onboarding & Ownership period
CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
FSN Capital ESG Report 2022
38
39
GOVERNANCE 
FRAMEWORK
1.  ROLES AND  RESPONSIBILITIES
Assign responsibilities
	·
Tone from the top: Chairperson, Board of 
Directors, and CEO
	·
ESG Officer/ESG Task Force 
3. CONTROLS
Implement control mechanisms
	·
Internal control
	·
External control
	·
Whistleblower channel
4. MONITORING AND  
COUNTERMEASURES
ESG on the agenda at every board meeting:
	·
Status on implementation of ESG policies
	·
Progress on ESG strategy action plan
	·
Progress on setting SBTs and action plan to 
reduce emissions
	·
Information on any ESG-related incidents
2.  PREVENTIVE MEASURES
Implement ESG Standard Policies
	·
Rules and Procedures for Board of Directors 
	·
CEO/management instruction 
	·
Code of Conduct
	·
Short version of Code of Conduct
	·
Supply Chain Code of Conduct 
	·
Whistleblower Policy + procedures for 
handling whistleblower reports 
	·
Authorisation Matrix: minimum require-
ments & annual auditor report
1. 
ROLES AND 
RESPONSIBILITIES
4. MONITORING 
AND COUNTER-
MEASURES
2. 
PREVENTIVE 
MEASURES
3.
CONTROLS
Implementation 
plan
Communicated 
to employees
Adopted 
by board of 
directors
Adopted by 
all subsidi-
aries
Training of 
relevant 
employees
Continuous 
improvement
The objective of the FSN Governance Framework is 
to ensure that FSN portfolio companies have good 
governance and operate in line with high ethical 
standards with a focus on continuous improvement. 
We have minimum requirements for all portfolio 
companies with regards to ESG policies, implemen-
tation, and governance. 
Our Governance Framework defines roles 
and responsibilities with clear expectations for 
the Chairperson, board of directors, and portfolio 
company management. The board of directors is 
always responsible for ensuring good governance and 
high ethical business conduct under the Governance 
Framework which entails adopting adequate ESG 
policies and ensuring implementation of these. The 
CEO is fully responsible for the daily management 
of the company, and that includes preparing the 
proposals on ESG to the board and to follow up with 
execution of plans. Further, since 2021 we require 
all portfolio companies to assign an ESG Officer to 
coordinate ESG initiatives across the organisation.
As part of the ESG onboarding program, manage- 
ment will, in close dialogue with FSN's deal team and 
ESG team, tailor fit FSN’s standard ESG policies and 
prepare a plan for implementation. FSN’s standard 
policies have been developed to enable portfolio 
companies to act in accordance with ethical standards 
and applicable laws and regulations, and were updated 
in 2022 to reflect recent changes in applicable laws 
and best practices in all core jurisdictions. The policies 
cover, inter alia, compliance with laws, human rights, 
anti-corruption, antitrust and sanctions. 
The implementation plan shall ensure integration 
of ethical standards throughout each portfolio 
company’s organisation and relevant operational 
processes  – with a focus on building ESG knowledge 
through training of employees. This approach seeks to 
ensure lasting change and improvement, and that FSN 
has a positive impact beyond our ownership period.
An important aspect of our Governance 
Framework is that ESG is expected to be the first thing 
on the agenda in every board meeting. This agenda 
item includes an update on status and progress under 
all three FSN ESG Frameworks. The board of directors 
is responsible for driving the ESG agenda and having 
it on the agenda keeps the momentum up.  Action 
plans under the three ESG Frameworks are subject to 
annual reviews and updates by the board of directors, 
and the same goes for the ESG policies. 
The FSN Governance Framework
PURPOSE: GOOD GOVERNANCE AND HIGH ETHICAL 
BUSINESS CONDUCT

Onboarding & Ownership period
CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
FSN Capital ESG Report 2022
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41
How to develop an ESG strategy 
Each FSN portfolio company management team 
creates an ESG strategy consisting of 3-5 material 
ESG focus areas with relevant KPIs. For each KPI, 
the management identifies both long (3-5 years) and 
short-term targets. The FSN Capital ESG team takes 
part in the discussions and development of every 
portfolio company’s ESG strategy. This also allows for 
sharing of best practice across the FSN portfolio.
Further, following the FEF process, each portfolio 
company is to create an ESG action plan to meet the 
annual targets under the ESG strategy. The action 
plan contains actions, clear responsibilities (owners), 
and the associated timeline. Progress on the ESG 
strategy is discussed in every portfolio company board 
meeting. The ESG strategy and action plan is subject 
to annual review and update.
FSN portfolio companies report on performance 
and disclose updated annual targets in the annual 
FSN ESG report. Please see Chapter 3 for the ESG 
strategies of each FSN portfolio company.
3-5 focus areas
Min 1 KPI per focus area
Performance per KPI
1 long-term target per KPI
Annual target per KPI
ACTION 
ITEM
OWNER
START 
DATE
DUE DATE
STATUS
TEAM/
COMMENTS
Description
Name
Date
Date
Green/
Yellow/Red
Text
FSN ESG STRATEGY 
STRUCTURE
FSN ACTION PLAN 
TEMPLATE
CONTINUOUS 
IMPROVEMENT
The FSN ESG Strategy Framework
PURPOSE: ENSURE POSITION  
AS A SUSTAINABILITY LEADER
We believe that to become a winner in any industry, 
you must also be a sustainability leader. The objective 
of the ESG Strategy Framework is to work with FSN 
portfolio companies to become sustainability leaders 
in their industry. The ESG Strategy Framework is an 
integral part of the FSN Execution Framework –  
FSN’s value creation approach (see fact box below).
The FSN ESG Strategy Framework results in 
an individualised ESG strategy for each portfolio 
company by mapping, prioritising and thereafter 
setting goals related to the material ESG topics for 
each company. The basis for this work is the ESG due 
diligence in which we identify material ESG topics for 
the company, what it takes to become a leader in these 
areas, and a status on the company’s current initiatives 
(see the ESG due diligence on p. 34).
Having a holistic ESG strategy allows portfolio 
companies to be agile as they see the bigger picture 
and can be proactive rather than reactive to emerging 
sustainability trends. We see that when management 
combines their deep industry expertise with the input 
from the ESG Strategy Framework, their strategic 
responses surpass our expectations. With this approach, 
ESG becomes an integral part of value creation, and 
the portfolio companies are more likely to also remain 
sustainable after FSN Funds’ ownership period.
FACT BOX: THE FSN EXECUTION  
FRAMEWORK (FEF)
The FSN Execution Framework (FEF) is FSN’s 
approach to driving value creation during our 
ownership period. FEF covers four main areas: 
Strategy, Organisation, Operations and Control, 
Reporting & Governance. The core of FEF is the 
FEF Strategy Process, a structured approach to 
developing, planning and executing with discipline 
on strategies that are clear, ambitious, prioritised and 
anchored in deep market insight. 
ESG is part of every step in implementing the FSN 
Execution Framework, from strategy to operations, 
control and reporting.
Following the FEF approach, FSN portfolio 
companies end up with a well-defined strategy and 
action plans - both overarching and within each key 
sub-topic such as ESG.    
To learn more about FEF, please visit our website: 
fsncapital.com

Onboarding & Ownership period
CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
FSN Capital ESG Report 2022
STEP 1
Map emissions
STEP 2
Set reduction targets 
& create action plan
STEP 3
Map reductions in emissions
REDUCE EMISSIONS
42
43
Part 1: The Climate Analysis Module
The Climate Analysis Module was inspired by the 
Taskforce on Climate-related Financial Disclosures 
(TCFD). We typically have external experts identify 
and analyse climate-related risks and opportunities 
in different temperature scenarios as part of the 
ESG due diligence phase (see p. 34). Scenarios are 
used to illustrate how climate change may affect the 
company and/or its value chain, whether in the form 
of physical risks in a high temperature scenario or due 
to transition risks and opportunities in a low temper-
ature scenario.
The insights from the climate analysis is shared 
with the portfolio company during the onboarding, 
with the goal to seek to ensure that portfolio 
companies prepare for climate change by assessing 
how climate change impacts their company through 
the full value chain. FSN Capital requires the impact 
of climate change to be discussed by all portfolio 
companies at board level.
Part 2: The Decarbonization Module
FSN Capital seeks to ensure that all portfolio 
companies commit to the Science Based Targets 
initiative (SBTi) within two years of acquisition, with 
efforts to set targets sooner where possible. In the due 
diligence phase we assess the Net Zero potential of the 
company, which forms the basis for our view on how 
to decarbonize the company in our ownership period 
(see p. 34). 
Through FSN’s Decarbonization Module we 
support portfolio companies’ decarbonization 
journeys. We utilise an online portal with expert 
support from external sustainability professionals. 
Portfolio companies report their GHG emissions in 
the portal, which is aligned with the Greenhouse Gas 
Protocol, and experts are available to assist and guide, 
should questions and challenges arise. Once a “base 
year” for measurement is established, the FSN Capital 
ESG team and external experts support portfolio 
companies in modelling how emissions reductions 
would look both economically and operationally, create 
an action plan for reduction, and set Science Based 
Targets aligned with the goals of the Paris Agreement.
PART 2. DECARBONIZATION MODULE
We support portfolio companies in setting Science Based Targets through our three-pronged approach 
The FSN Climate Framework
PURPOSE: TO PREPARE PORTFOLIO 
COMPANIES FOR A NET ZERO FUTURE
PHYSICAL RISKS
Arising from climate and 
weather-related events
TRANSITION RISKS
Arising from the process of 
the adjustment towards a 
low-carbon economy
PART 1. CLIMATE ANALYSIS MODULE  
Climate scenarios in three temperatures as recommended by TCFD 
Obton, one of Europe’s largest solar power developers, 
and ViaCon, whose storm water solutions are likely to 
be increasingly necessary as we adapt to a changing 
climate.
In addition to investing in companies that seek to 
address climate challenges, we have also developed 
the FSN Climate Framework. There are two parts to 
the framework - as illustrated below and described to 
the right.
We believe that climate change is the greatest 
challenge and opportunity of our time. 
One of our key strategies for supporting the 
transition to a low-carbon economy is to invest in 
companies that directly contribute to or enable 
climate change mitigation and/or adaptation through 
their products and/or services. Examples of FSN 
portfolio companies that directly address climate 
challenges include Polytech, a provider of systems 
to protect and improve efficiency of wind turbines,

FSN Capital ESG Report 2022
CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
44
45
EXAMPLE:
DUE DILIGENCE OF A 
TEXTILE COMPANY
In 2020 we looked at acquiring a textile company 
with a production and supplier base in Europe and 
MENA. We identified that the inherent human rights 
risks for this company were high, not only because 
of its industry, but also because of the jurisdictions 
where the production and tier-1 suppliers were based. 
Human rights risks included workers’ rights, working 
hours, remuneration, and health and safety. To address 
these risks, the company in question had mandated 
its manufacturers to be compliant with third-party 
social auditing schemes. However, given the high 
risk in these jurisdictions, we saw it as imperative 
to thoroughly investigate the sites during our due 
diligence phase.
Given that the COVID-19 pandemic had the world 
in lockdown, neither we nor our trusted advisers could 
conduct site visits. As such, we had to get creative: a 
full vendor ESG due diligence was initiated as well 
as the customary audits, and we accessed videos and 
pictures of the production site to get an overview of the 
situation. Critically, we interviewed current and former 
employees at the production and supplier sites using 
discrete sources to get a feel for the conditions there. 
We also conducted interviews with local authorities.
Our thorough investigation found no human rights 
violations, but we did see a need to improve site condi-
tions to meet our standards. Following our investment 
philosophy, we looked at this case as an opportunity to 
have a positive impact on people’s lives, rather than to 
disregard the company or to move production to lower 
risk jurisdictions.
As per our standard process, the deal team 
created a detailed action plan. In addition to running 
the company through the FSN ESG Governance 
Framework to implement our standard policies 
that address human rights (e.g., Code of Conduct, 
Supplier Code of Conduct and whistleblower policy) 
and conducting mandatory supplier screens and 
audits through verified third parties, the deal team 
committed to sending one representative to visit the 
sites in person once COVID-19 restrictions would 
allow. If insufficient social standards were identified 
in the supply chain, a corrective action plan would 
be demanded, and if this plan was not implemented 
the supplier would be replaced as a last resort. 
Further, human rights certifications like the Fair Wear 
Foundation would be obtained. The deal team also 
committed to be directly involved in the process, as 
well as appointing a dedicated person with relevant 
experience for the daily management of ESG and 
human rights at the company level. Although we 
ended up not doing the deal, our ESG due diligence 
framework positioned us to make an educated 
decision and be prepared to be responsible owners 
from day one.
CASE STUDY 
ESG due diligence with 
focus on human rights
This is a short version of a case study written for UN PRI. 
The full case study can be found here. 
Our ESG due diligence scope follows UN’s Guiding 
Principles for due diligence. In the due diligence 
phase, we identify and assess potential and actual 
human rights risk in a company’s operations and 
supply chain. To ensure that key risks are accurately 
accounted for, we always involve external ESG experts 
to conduct the due diligence and ask that they use our 
standard ESG due diligence framework (see below and 
p. 34 for more details).
A company's entire value chain is subject to 
review: its' in-house operations, partners, suppliers, 
and customers. Indicators for high human rights 
risk include operating in countries with historically 
poor/limited employee protection and low labour 
standards, labour-intensive work, and high volume 
and/or low-cost products. The external ESG experts 
use a range of sources, including Transparency 
International, Human Rights Watch, Amnesty 
International, industry reports and company websites.
The assessment of the inherent risk profile dictates 
the ESG due diligence scope and thereby which 
areas we focus our efforts on. To understand how the 
potential investment currently addresses the identified 
risks, external experts do a combination of management 
sessions, interviews with discrete sources, question-
naires, and on-site due diligence. After assessing how 
the target addresses the current risks, residual ESG 
risks are rated from high to low. Finally, we ask the ESG 
experts to provide their recommendations for how to 
address the residual risks. This last step is critical when 
building an action plan for how to integrate, act and 
follow up on risks in our ownership period.
Inherent ESG risk 
profile
Target's current 
mitigating actions
Target-specific 
residual ESG risk
ESG experts' 
recommendations
The case studies presented herein and any information relating to ESG or climate 
performance are for illustrative purposes only. They do not represent a full list 
of FSN Capital portfolio companies, and should not be seen as an indication of 
current or future performance.

CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
FSN Capital ESG Report 2022
46
47
Active Brands is a proud agent for change in the sports apparel and equipment industry. 
The fast-growing house of brands includes Kari Traa, Dæhlie, and Sweet Protection,  
and has over the years systematised its sustainability and ESG efforts. In 2022 it became 
the first FSN portfolio company to have its emission reduction targets verified by the 
Science Based Targets Initiative (SBTi). Active Brands has been an FSN portfolio company 
since 2017, first through FSN Capital IV and currently through FSN Capital VI.
 
We spoke with Rebecca Johansson, Head of ESG and Sustainability at Active Brands,  
about the company’s race to Net Zero:
Why did you decide to set Net Zero 
targets?
At Active Brands, we understand the impacts of 
climate change and how rising temperatures can affect 
our business. Therefore, we have worked proactively 
with ESG, aiming at aligning our business priorities 
with climate action in all parts of our company. 
Naturally, this involves reducing our negative impact 
and becoming net zero.
Our ESG work accelerated through the ESG 
onboarding with FSN Capital. With the right amount 
of guidance, we have systematically turned our ESG 
ambitions into action. Through the double materiality 
analysis in the FSN ESG Strategy Framework we 
identified climate action as one of the most critical 
areas to focus on. Further, when FSN Capital set its 
CASE STUDY
Active Brands’ Race 
towards Net Zero
The case studies presented herein and any information relating to ESG or climate 
performance are for illustrative purposes only. They do not represent a full list 
of FSN Capital portfolio companies, and should not be seen as an indication of 
current or future performance. 
Science Based Targets in 2021, we received support 
to set our own SBTs: through the FSN Climate 
Framework we had already started reporting our 
emissions, and got support from external consultants 
and FSN to formalise a clear plan for mapping 
emissions across our seven brands, setting reduction 
targets, and creating an action plan. 
What were some of the roadblocks to set 
SBTs and how did you overcome them?
One of the main challenges was, and still is, to obtain 
accurate data of our emissions. In terms of scope 1 & 2 
emissions (our own operation), we have direct access 
to the emitting sources and can thereby more easily 
ensure the quality of data. However, when mapping 
scope 3, we have had limited access to factual data.
Initially, we assessed life cycle assessments of 
certain raw materials, while also keeping record of 
the exact type and weight of every element - down 
to the smallest trims, such as cord stoppers, buttons, 
and threads. This detailed tracking enabled us to 
develop roadmaps for each brand with its unique raw 
material and product mix. In the cases where we did 
not have access to such information, we had to rely 
on global averages. Thereby, we acknowledge data 
gaps where we have had to rely on estimates rather 
than actual data. However, we work to counteract 
such gaps by continuously building our supply chain 
on long-term partnerships. Our strong relationship 
with key suppliers gives us access to some of their 
data on a facility level, including their actual energy 
consumption and sources. Although this provides a 
good indication of our key sources of emissions we 
must continue to strive for more reliable data. 
How will you meet your ambitious Net Zero 
targets?
To reach our 2025 target we know that renewable 
energy and an electrification of our company carpool 
is what will bring us to our goal. For our 2030 target, 
we have developed a high-level roadmap and begun 
to customise a plan for each brand. We will break 
down our targets into sub-targets to get each team to 
know what specific actions are required by them to 
cut emissions in the value chain. Climate and GHG 
emission considerations must be built into every 
function and team and be a part of daily business 
decisions. Communication is in our view key to make 
sure the full organisation is aligned and working 
towards the same goal.   
Achieving Net Zero targets in the full value chain 
by 2050 cannot be done alone. In addition to the work 
we do with our suppliers in the value chain, Active 
Brands also seeks to collaborate with industry peers and 
business partners. In 2021 we joined STICA (Swedish 
Textile Initiative for Climate Action). This industry 
collaboration brings together nearly 50 brands and 
companies from the textile industry to share knowledge, 
drive initiatives, and tackle climate challenges in the 
shared supply chain. This type of work must continue, 
as we are all dependent on the global value chains to 
embark on the same Net Zero journey to mitigate the 
severe consequences of climate change. 
Although there are many unknowns, we are 
energised by the momentum of climate action and 
will be working steadfastly towards our Net Zero 
commitment. 
For Active Brands’ full ESG Strategy,  
please see p. 58 
Active Brands’ ambitious emissions targets:
	·
Net Zero in own operations by latest 2025 (Scope 1-2)
	·
Reducing 60% GHG emissions in Scope 1-3 per product by 2030
	·
Net Zero emissions across the full value chain by latest 2050

“This is the future. For example, restoring floors 
rather than changing them saves about 7 kg of carbon 
emissions per tenth square metre. These solutions make 
us an even better partner for our customers,” says 
Business Development Director Elisabeth Rustad-
Nilssen. Other examples of sustainable solutions for 
customers include offering environmentally friendly 
materials and ESG KPI dashboards.  
At HG, providing good work conditions and 
developing employees is a priority. A learning platform 
available for all employees, the HG Academy, was 
launched in 2021. The HG Academy provides the 
necessary tools and training to develop both soft and 
hard skills, within areas such as project management 
and leadership, leading to increased job satisfaction 
and personal growth. In 2022, 342 employees 
completed training at the HG Academy, while the 
measured eNPS was 46.  
HG is also proud to support apprentices (about 
9.2% of its total workforce), providing the opportunity 
for training and work security. Apprentices who join 
HG are not only youths coming straight from school, 
but also adults who are looking for a new path. At 
HG they get the necessary training to become a 
craftsperson.  
 “At HG, we care for each other. That means we want 
what’s best for the people around us.  It means we care 
for the environment we operate in. It means we care 
about doing things right,” says CEO Øyvind Emblem. 
Looking ahead, HG’s quest to change the industry 
and be “Proud craftspeople leading the way” drives 
them to evolve. In parallel to continuously onboarding 
new companies to HG’s ESG standards, the company 
is doubling down on its climate efforts. Starting from 
2023, HG is implementing quarterly reporting on 
CO2 emissions for all companies and will be setting 
science-based targets. 
For HG’s full ESG Strategy, please see p. 74
Winner of FSN Capital’s 2022 
ESG Award – Håndverksgruppen
Proud craftspeople leading the way
FSN’s annual ESG award is part of setting the tone from the top. 
Netcompany, Saferoad, Kjell & Company, Mørenot, and ViaCon, 
amongst others, are all proud winners from previous years.
The criteria for selecting the winner remain unchanged:
	·
Awareness and ESG efforts in daily operations
	·
Value creation in society at large
	·
Clarity in ESG policies
	·
Focus on continuous improvement and progress
	·
Tone from the top (i.e., management and board engagement)
	·
Portfolio Company’s holistic approach to sustainability
	·
Adherence to FSN Capital’s values 
This year’s ESG award winner is Håndverksgruppen 
(HG), Nordic's largest provider of surface treatment 
services including painting, flooring, tiling and 
masonry. HG was established in 2020 when FSN 
Capital V partnered with around 30 companies 
to form a group of local winners and give them 
access to the benefits of a larger platform, while still 
maintaining an entrepreneurial spirit through HG’s 
decentralised structure. Today the group totals more 
than 3000 employees in over 100 operating companies.
With ESG firmly integrated in its core commercial 
approach, a strong tone from the top, and a desire 
to continuously improve, HG has proved itself a 
worthy recipient of this year’s award. ESG is a clearly 
understood value driver to be the best business partner 
to its customers, and it further serves as a lever to 
attract and retain the best companies and people to 
join the HG group. HG is changing a whole industry, 
professionalising and heightening the standards for all 
players, for the benefit of the whole society. HG is a 
sustainability leader with strong governance and high 
ethical standards, and has an ambitious ESG agenda 
not only because it’s the right thing to do – it is simply 
good business.
With, on average, one company added to the group 
every second week, HG is on a continuous journey to 
ensure that ESG is a priority within all new add-ons. 
ESG is a critical due diligence workstream in HG’s 
M&A process, and the company has walked away from 
potential add-ons due to ESG concerns. At the same 
time, many companies are attracted to join the group 
due to its approach to ESG.
Similarly, one of HG’s key value propositions to 
public and professional B2B customers is its ESG 
focus, offering high quality services, with clear ethical 
standards and strong Health, Safety and Environment 
(HSE) compliance and documentation. All HG 
companies need to be ISO14001 certified within 
12 months after joining the group. Acknowledging 
its industry’s footprint, HG challenges established 
practices and innovates to meet customer needs. In 
2022, HG launched “Sustainable solutions” which are 
common services designed to resolve a problem with a 
minimal footprint and at a lower cost.   
The case studies presented herein and any information relating to ESG or climate 
performance are for illustrative purposes only. They do not represent a full list 
of FSN Capital portfolio companies, and should not be seen as an indication of 
current or future performance.
CHAPTER 2 — ESG Integration Throughout the Investment Lifecycle 
FSN Capital ESG Report 2022
48
49

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
50
51
CHAPTER 3
ESG 
Developments 
in FSN Portfolio 
Companies
A detailed view on how FSN portfolio companies 
work systematically on environmental, social, and 
governance topics

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
52
53
1.	
Professional board members (excludes minority shareholders, 
FSN Capital employees, and employee representatives); 
2.	
Have a written code of conduct that they share  
with employees;	
3.	
Have trained employees in Code of Conduct, e.g., ethics, anti 
bribery and corruption; 	
4.	
Have a written Supplier Code of Conduct that they share 
with suppliers; 	
5.	
Have a written whistleblower policy that they share  
with employees; 
6.	
Electronic and/or hotline whistleblower 
	
*Excludes holdings in listed companies
**Bäcker Görtz acquired in Q4 2022 - FSN standard policies currently being implemented
The case studies presented herein and any information relating to ESG or climate performance are for illustrative purposes only.  
They do not represent a full list of FSN Capital portfolio companies, and should not be seen as an indication of current or future performance.
72%
33%
67%
–
1
60
54%
0%
25%
5.9%
–
–
56%
0%
33%
4.4%
–
–
26%
36%
0%
3.6%
5
–
48%
14%
50%
–
57
48
27%
33%
0%
3.9%
26
42
32%
11%
50%
6.5%
31
55
9%
17%
67%
9.6%
7
–
18%
25%
0%
2.4%
15
–
8%
17%
33%
6.7%
46
48
72%
0%
50%
5.2%
–
–
16%
0%
25%
6.5%
33
55
42%
29%
0%
–
36
–
29%
50%
25%
–
22
–
16%
20%
25%
3.7%
29
27
37%
27%
33%
1.8%
50
–
23%
14%
50%
–
60
–
39%
0%
50%
4.3%
-1
28
20%
8%
33%
4.9%
–
55
19%
0%
50%
5.3%
29
–
16%
14%
50%
3.4%
–
33
30%
14%
0%
–
–
44
33%
20%
40%
2.7%
10
–
28%
29%
25%
– 
19
–
20%
0%
50%
5.0%
-7
–
92%
96%
48%
92%
96%
84%
% Female FTEs
% Female C-suite 
officerss
% Females on BoD1
Absenteeism (%)
Employee Satisfaction (eNPS)
Customer Satisfaction (cNPS)
ESG at all board meetings
Code of Conduct2
Code of Conduct Training3
Supplier Code of Conduct4
Whistleblower Policy 5
Whistleblower System6
NON-FINANCIAL KPIS 
AS OF 31.12.2022
ESG KPIs for FSN
Portfolio Companies
OVERVIEW OF FSN PORTFOLIO COMPANIES AS OF 31.12.2022*
Active Brands
House of premium sports apparel and equipment brands 
129
240
Adragos Pharma
A globally operating B2B Contract Development and Manufacturing  
Organisation (CDMO) 
43
392
Bäcker Görtz** 
Leading German bakery chain offering a tailored product assortment of baked 
goods and out-of-home meals
142
1718
ecovium
End-to-end logistics software and hardware provider
51
394
Epista Life Science
IT services and consultancy firm dedicated to the Life Science industry
18
119
Fellowmind
A leading Microsoft partner in Europe focusing on adoption of digital innovation 
and cloud transformation
299
1946
Fibo
Leading global manufacturer of high-quality wet room wall systems
86
155
Firesafe
Leading Nordic supplier of fire protection services
122
968
Gram Equipment
A global market leader within advanced ice cream processing equipment
126
544
Håndverksgruppen
The Nordic's largest provider of surface treatment services including painting, 
flooring, tiling, and masonry
466
3042
Holmbergs
A global supplier of mission critical safety systems to the child safety  
seat industry
68
983
IMPREG
A leading supplier of glass fiber liners for sustainable and environmentally 
friendly sewage rehabilitation
88
304
Koncenton
Leading investment provider of residential real estate projects
20
108
MEGABAD
Leading German e-commerce retailer for bathroom and sanitary products
193
259
Nordlo Group
Nordic IT and digitalisation partner helping customers improve  
their IT environment
171
834
Obton
Leading Danish alternative asset manager and developer with focus on solar PV
110
297
Omegapoint
Market leading cyber security and secure digital transformation consultancy
113
844
OptiGroup
Leading European distribution group offering customised supply solutions  
to B2B customers
1652
2387
Rameder
Leading European e-commerce platform for automotive transport products  
and solutions 
123
366
Saferoad
The largest supplier of road safety and road infrastructure solutions in Europe
586
2501
Seriline
Leading provider of physical access management systems for secure  
access control 
14
51
Skamol
Leading producer of energy-saving, high temperature insulation products  
to customers globally
85
409
SneakersNStuff
A global online and physical retailer of limited edition sneakers and apparel
96
164
TASKING
Global provider of compilers, linkers and debuggers for automotive  
and industrial applications
27
90
ViaCon
The European market leader of engineered corrugated steel structures  
and pipes used to build e.g. culverts, bridges and tunnels
211
776
Total (Yes)
19891
Revenue (EURm)
Employees (FTEs)

PORTCO NAME
SCOPE 1
COMPLETE 
SCOPE 1 
REPORTING*
SCOPE 2
COMPLETE 
SCOPE 2 
REPORTING*
SCOPE 3
ALL 
MATERIAL 
SCOPE 3 
CATEGORIES*
COMMITTED 
TO SCIENCE 
BASED 
TARGETS 
INITIATIVE
GHG 
EMISSIONS 
INCLUDED 
IN ESG 
STRATEGY
Active Brands
77
51
43,712
✓
✓
Adragos Pharma
2,136
1215
595
–
✓
Bäcker Görtz**
–
–
–
–
–
ecovium
246
204
211
–
✓
Epista
–
–
–
–
✓
Fellowmind
1,427
174
1,381
–
✓
Fibo
93
39
198,847
–
✓
Firesafe
1,761
24
786
–
✓
Gram
479
367
3,847
–
✓
Håndverksgruppen
4,051
104
3,970
–
✓
Holmbergs
670
1,560
1,438
–
✓
IMPREG
376
542
93,140
–
✓
Koncenton
2
6
1
–
✓
MEGABAD
203
92
12,798
✓
✓
Nordlo
74
156
8,387
✓
✓
Obton
2
41
334
–
✓
Omegapoint
88
38
522
–
✓
OptiGroup
7,002
6,131
7,950
–
✓
Rameder
188
317
5,410
–
✓
Saferoad
13,692
3,343
311,708
✓
✓
Seriline
55
2
16
–
✓
Skamol
22,703
2,832
37,753
–
✓
SNS
–
0.4
12,771
–
✓
TASKING
–
15
4
–
✓
ViaCon
1,823
2,546
9,786
✓
✓
Total
57,148
19,799
755,367
Most units/categories
Yes
Limited reporting 
GHG emissions reported in online portal.  
Any estimates are conducted by CEMAsys in line with the GHG Protocol 
*  Complete scope and material categories according to the GHG Protocol
** 	 Bäcker Görtz acquired in Q4 2022
CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
54
55
GREENHOUSE GAS EMISSIONS FOR  
FSN PORTFOLIO COMPANIES 2022 (tCO2e)
STEP 1
Map emissions
BASELINING
	·
All portfolio companies have completed scope 3 screenings*
	·
All portfolio companies are familiar with and working on estab-
lishing a solid base year to set a Science Based Target
	·
Reporting is based on good data quality and gathering of activity and/
or supplier data, rather than cost estimates, leading to more accurate 
reporting
STEP 2
Set reduction targets 
& create action plan
COMMITMENTS 
	·
5 portfolio companies have committed to the Science Based Targets 
initiative, others in progress
	·
All portfolio companies have identified GHG emissions reductions as 
a material topic for them and are working towards setting reduction 
targets
STEP 3
Map reductions in 
emissions
REDUCTION EXAMPLES 
	·
ViaCon’s total emissions went down by 10% relative to 2021, through 
initiatives such as reducing consumption of virgin plastic and steel 
(see ESG strategy p. 104)
	·
Skamol reduced all three scope emissions by more than 5% relative 
to 2021, by screening individual production plants and identifying 
tailored reduction initiatives (see ESG strategy p. 98)
	·
Fibo reduced both scope 1 & 2 emissions by ~20% from 2021 by 
limiting the idle time of equipment and machinery, and purchasing 
Renewable Energy Certificates (RECs)  (see ESG strategy p. 68)
FSN Capital is committed to support FSN portfolio companies 
in setting Science Based Targets and reducing their emissions 
accordingly. Below is an update on the status in the FSN portfolio. 
FSN’S 
DECARBONIZATION 
MODULE	
	
Status of FSN Portfolio Companies' 
Decarbonization Journeys
STATUS IN FSN PORTFOLIO
* except newly acquired companies

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
56
57
ESG STRATEGY
CHAPTER 3 — ESG Developments in FSN Portfolio Companies
61
End all forms of discrimination against all women and girls 
(5.1). Ensure women’s full and effective participation and 
equal opportunity for leadership at all levels of decision-
making (5.5)
Promote mental health and well-being (3.4)
FOCUS 
AREA
KPIS
LONG TERM 
TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Sustain-
able value 
chain 
 • 1a. % of manufacturers with 
climate targets and action 
plans in place
 • 1b. GHG emission reductions 
(absolute Scope 1,2 and % 
Scope 3)
 • 1c. % of environmentally 
preferred materials in 
products
 • 1d. Identify how to measure 
water, chemistry, waste, and 
biodiversity impact 
 • 1e. Enhance ESG reporting
 • 1f. Supply chain transparency 
T1 and T2, on open platform 
and % of products covered 
 • 1a-c. Deliver on 
our SBTi Net-Zero 
Climate Target
 • 1d. Systematically 
measure and 
disclose water, 
chemistry, waste, 
and biodiversity 
impact according to 
targets
 • 1e-f. Demonstrate 
transparency and 
accountability on 
ESG
 • 1a & b. Calculated Scope 1,2, and 3 GHG emission 
baseline (set to 2021) and got SBTi approval for 
our net-zero climate target. Developed climate 
strategy with a high-level roadmap to net zero for 
each brand 
 • 1c. RDS (responsible sourced down): 100%, Merino 
wool: IWTO cert non-mulesing: 100%, Bluesign 
approved fabrics: 20% all, 30% synthetics
 - Oekotex cert fabrics: 75%, Recycled Polyester: 12% 
(compared to polyester volumes) – refers to 2021 
volumes
 • 1d. Conducted high-level risk assessment including 
water, waste, and biodiversity. Approved bluesign 
system partnership.
 • 1e. Ethical Trade Norway report
 • 1f. Full mapping of Tier 1 and Tier 2 initiated to be 
ready Feb 2023
 • 1a. Min 40% of key suppliers 
have their own climate targets 
and action plans in place
 • 1b. Min 30% absolute 
reduction in Scope 1 and 2
 • 1c. Set & follow clear reduction 
targets per AB brand
 • 1d. Join the bluesign system
 - Adopt regenerative merino 
wool and develop an adoption 
plan 
 • 1e. Deliver AB ESG report with 
reference to GRI
 • 1f. Full mapping of T1 and T2 
supplier facilities and sharing 
of locations on product and 
open platform
2. Products 
and services 
 • 2a. Establishing the 
guidelines
 • 2b. Number of products sold 
via our resell platform
 • 2c. Repair offering:
 - Consumer engagement in 
repair DIY guidance and 
repair kits
 - Number of products repaired 
via customer service
 • 2d. % reduction of packaging
 • 2a-d. Incorporate 
circular principles 
in every product 
creation and 
circular models 
(re-com & repair) 
in every key market
 • 2a. Conducted two larger workshops focusing on 
how to keep the products active and longlived and 
continued implementation of the digital 3D design 
tool.
 • 2b. Signed partner agreement with resell provider 
Vandre.
 • 2c. “Norwegian Sportswear Innovation Initiative” 
resulted in a project funded by Viken county which 
focuses on repair offers. Began mapping repair 
service possibilities and projects to enable repairs. 
Launch delayed to 2023. 
 • 2d. Extensive measuring of packaging materials; 
cardboard, paper and LDPE
 • 2a. Develop sustainability 
guidelines for design & 
development, and communi-
cation guidelines for customer 
service/marketing
 • 2b. Pilot resell in key markets 
(Norway and US)
 • 2c. Extend and structure our 
repair offering
 • 2d. Initiate packaging 
reduction project
3. Health
 • 3a. Number of engagement 
initiatives
 - Number of people involved 
in the initiatives related to 
physical activity
 • 3b. eNPS
 • 3c. Winningtemp score 
 • 3a-c. Active Brands 
is rated to be 
among the most 
attractive places 
to work in the 
sporting goods 
industry and a 
leader in engaging 
people toward a 
healthier lifestyle
 • 3a. KT: “Boobs on my mind” – a campaign in 
support of the breast cancer cause. 
 - BD: “Team Beyond” – one team beyond abilities, 
gender, age, nationality, and disciplines
 - Åsnes: supporting the documentary “Draumen om 
Grønland”
 - Bula: brought in a new ambassador which for him 
was life-changing 
 - JO: Supported Norwegian Cancer Organization 
battling breast cancer. Launched the podcast 
“Johaug Redaksjonen” which focused on training 
and mental health.
 • 3b. eNPS: 1/100 
 • 3c. Winningtemp Temp score: 7.3/10
 • Winningtemp response rate: 76-84%r
 • 3a. Engage consumers and 
people in physical activity
 • 3b. Stabilise eNPS towards 
industry level
 • 3c. Increase Winningtemp 
score by 15%
4. Human 
rights
 • 4a. T1 suppliers audited 
with BSCI or similar audit 
schemes
 • 4b. Salient human rights 
issues, qualitative progress
 • 4a & b. Active 
Brands support 
and protect human 
rights in our supply 
chain, with a focus 
on identified salient 
human rights issues
 • 4a. All vendors audited in person via BSCI in 2022: 
58% by number of vendors, 93% by volumes.
 - Vendors outside Europe audited via BSCI in 2022: 
67% by number of vendors, 94% by volume
 • 4b. Developed and implemented Active Brands 
Responsible Business Conduct Policy. Updated 
materiality assessment ongoing and will continue 
during Q1 ‘23
 • 4a. 75% of Tier 1 suppliers, 
outside Europe, were audited 
with BSCI or similar audit 
schemes
 • 4b. Identifying salient human 
rights issues and developing 
an action plan and targets to 
address them
ACTIVE BRANDS ESG STRATEGY 2023 
Active Brands has selected the following SDGs to which it has an opportunity to contribute:
Protect labour rights and promote safe and secure working 
environments for all workers (8.8), and facilitate equal pay 
for work of equal value (8.5). Take measures to eradicate 
forced labour, end modern slavery and human trafficking, 
and secure the prohibition and elimination of the worst 
forms of child labour(8.7)
Achieve sustainable management and efficient use of 
natural resources (12.2) and reduce waste generation 
through prevention, reduction, recycling, and reuse (12.5)
Mobilise and share knowledge, expertise, technology, and 
financial resources, to support the achievement of the 
Sustainable Development Goals (17.16)
ESG STRATEGY: 
Based on the materiality analysis, 
each portfolio company creates an 
ESG strategy centred around 3-5 
focus areas, with KPIs and long 
and short term targets. Portfolio 
companies also transparently 
disclose 2022 performance.
SDG MAPPING: 
The portfolio companies further 
disclose which SDGs they have 
an opportunity to contribute to 
based on an assessment conducted 
by external experts. This is not an 
indication of actual contribution 
unless otherwise explicitly stated. 
Structure of the ESG 
Strategy 2-pager 
Following FSN’s ESG Strategy Framework, each portfolio company 
creates its own tailormade ESG strategy based on thorough analysis 
and materiality assessment (see p. 40 for information on the ESG 
Strategy Framework). On the next pages you will find each portfolio 
company’s ESG Strategy reported in a 2-pager format. 
ESG ANALYSIS
FSN Capital ESG Report 2022
60
 FSN Portfolio Company since 2017
activebrands.com
Active Brands is a leading Nordic supplier of sporting goods brands 
and promotes seven own brands. The Active Brands’ product portfolio 
consists of a variety of sports apparel, and equipment related to an active 
lifestyle. Norway is currently the company’s biggest market, while Sweden 
and North America represent the second and third largest end-markets. 
Whereas the company’s main customer group is B2B (serving sporting 
goods e-tailers and retailers), the fastest growing route to market is repre-
sented by Active Brands’ own web shops.
Main raw materials include animal products like wool and goose down, 
as well as cotton and certain synthetic fabrics. Active Brands sources 
raw materials globally, and products are manufactured by third-party 
producers, most of which are found in Asia.
Active Brands’ potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS 
& SUPPLIERS 
∙ Water depletion and pollution in 
the cotton supply chain
∙ Water use during textile production
∙ Local pollution from chemicals in 
textile production (e.g. dyeing)
∙ GHG emissions and energy use in 
material production 
∙ Animal welfare in wool and down 
production
∙ Labour and human rights
∙ Health and safety of workers
∙ Socioeconomic impact of 
corruption and bribery in the 
supply chain
PRODUCT
ASSEMBLING
 
∙ Local pollution from chemical use in 
product assembling
∙ GHG emissions and energy use 
from product assembling
∙ Material waste in production
∙ Packaging waste (paper, plastic)
∙ Labour and human rights in 
garment factories
∙ Health and safety in garment 
factories
∙ Work-life balance
∙ Diversity and inclusion
MANAGEMENT  
& MARKETING
 
∙ GHG emissions from inbound and 
outbound logistics
∙ Energy use in sales offices and 
stores
∙ Employee commuting and business 
travel
∙ Office waste
∙ Textile waste from outdated 
collections
∙ Work-life balance
∙ Diversity and inclusion
∙ Social impacts of marketing 
activities (body image, 
representation)
∙ Anti-corruption and bribery
CUSTOMERS 
& END-USERS
∙ Microfiber pollution during the 
washing of textile products
∙ Textile waste from used/torn 
garments
∙ Longevity of products
∙ Packaging waste (paper, plastic)
∙ Product health impacts in use (e.g. 
toxins)
∙ Contributing to sport safety
∙ Active and healthy lifestyles
∙ Contract conditions (B2B 
customers)
Initial EU taxonomy assessment
Key activities
∙ C14.1 - Manufacture of wearing apparel
∙ G46.4 - Wholesale of textiles, clothing, and footwear
External factors impacting Active Brands based 
on its sector, jurisdictions, and operations
 
+ Demand for low impact and circular products produced in socially 
sustainable ways
 
+ Active lifestyle associated with positive health outcomes 
 - Scrutiny of the environmental footprint of the textile industry
 - Climate change causing shifts in seasons, impacting consumption 
patterns and demand, and risk of causing disruption in the supply chain
 - Scrutiny of human rights and labour conditions in the supply chain
Potential contribution to environmental objective
∙ Transition to a Circular Economy
PORTFOLIO COMPANY  
DESCRIPTION:
Covering business activities, 
geographic footprint of value chain, 
and key customers.
DOUBLE MATERIALITY 
PART 1/2: 
Analysis of the portfolio company’s 
potential impact on the world 
across the full value chain – looking 
at both positive and negative 
impacts from an environmental, 
social, and governance perspective.
DOUBLE MATERIALITY 
PART 2/2: 
External ESG factors that may 
impact a portfolio company due 
to its sector, jurisdiction, and 
operations.
INITIAL EU TAXONOMY 
ASSESSMENT:
High level outside-in eligibility 
assessment conducted by external 
experts.
Importance to Stakeholders
Importance to Company

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
58
59
End all forms of discrimination against all women and girls 
(5.1). Ensure women’s full and effective participation and 
equal opportunity for leadership at all levels of decision-
making (5.5)
Promote mental health and well-being (3.4)
FOCUS 
AREA
KPIS
LONG TERM 
TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Sustain-
able value 
chain 
	• 1a. % of manufacturers with 
climate targets and action 
plans in place
	• 1b. GHG emission reductions 
(absolute Scope 1,2 and % 
Scope 3)
	• 1c. % of environmentally 
preferred materials in 
products
	• 1d. Identify how to measure 
water, chemistry, waste, and 
biodiversity impact 
	• 1e. Enhance ESG reporting
	• 1f. Supply chain transparency 
T1 and T2, on open platform 
and % of products covered 
	• 1a-c. Deliver on 
our SBTi Net-Zero 
Climate Target
	• 1d. Systematically 
measure and 
disclose water, 
chemistry, waste, 
and biodiversity 
impact according to 
targets
	• 1e-f. Demonstrate 
transparency and 
accountability on 
ESG
	• 1a & b. Calculated Scope 1,2, and 3 GHG emission 
baseline (set to 2021) and got SBTi approval for 
our net-zero climate target. Developed climate 
strategy with a high-level roadmap to net zero for 
each brand 
	• 1c. RDS (responsible sourced down): 100%, Merino 
wool: IWTO cert non-mulesing: 100%, Bluesign 
approved fabrics: 20% all, 30% synthetics
	- Oekotex cert fabrics: 75%, Recycled Polyester: 12% 
(compared to polyester volumes) – refers to 2021 
volumes
	• 1d. Conducted high-level risk assessment including 
water, waste, and biodiversity. Approved bluesign 
system partnership
	• 1e. Ethical Trade Norway report
	• 1f. Full mapping of Tier 1 and Tier 2 initiated to be 
ready Feb 2023
	• 1a. Min 40% of key suppliers 
have their own climate targets 
and action plans in place
	• 1b. Min 30% absolute 
reduction in Scope 1 and 2
	• 1c. Set & follow clear reduction 
targets per AB brand
	• 1d. Join the bluesign system
	- Adopt regenerative merino 
wool and develop an adoption 
plan 
	• 1e. Deliver AB ESG report with 
reference to GRI
	• 1f. Full mapping of T1 and T2 
supplier facilities and sharing 
of locations on product and 
open platform
2. Products 
and services 
	• 2a. Establishing guidelines
	• 2b. Number of products sold 
via our resell platform
	• 2c. Repair offering:
	- Consumer engagement in 
repair DIY guidance and 
repair kits
	- Number of products repaired 
via customer service
	• 2d. % reduction of packaging
	• 2a-d. Incorporate 
circular principles 
in every product 
creation and 
circular models 
(re-com & repair) 
in every key market
	• 2a. Conducted two larger workshops focusing on 
how to keep the products active and longlived and 
continued implementation of the digital 3D design 
tool
	• 2b. Signed partner agreement with resell provider 
Vandre
	• 2c. “Norwegian Sportswear Innovation Initiative” 
resulted in a project funded by Viken county which 
focuses on repair offers. Began mapping repair 
service possibilities and projects to enable repairs. 
Launch delayed to 2023
	• 2d. Extensive measuring of packaging materials; 
cardboard, paper and LDPE
	• 2a. Develop sustainability 
guidelines for design & 
development, and communi-
cation guidelines for customer 
service/marketing
	• 2b. Pilot resell in key markets 
(Norway and US)
	• 2c. Extend and structure our 
repair offering
	• 2d. Initiate packaging 
reduction project
3. Health
	• 3a. Number of engagement 
initiatives
	- Number of people involved 
in the initiatives related to 
physical activity
	• 3b. eNPS
	• 3c. Winningtemp score 
	• 3a-c. Active Brands 
is rated to be 
among the most 
attractive places 
to work in the 
sporting goods 
industry and a 
leader in engaging 
people toward a 
healthier lifestyle
	• 3a. KT: “Boobs on my mind” – a campaign in 
support of the breast cancer cause
	- BD: “Team Beyond” – one team beyond abilities, 
gender, age, nationality, and disciplines
	- Åsnes: supporting the documentary “Draumen om 
Grønland”
	- Bula: brought in a new ambassador which for him 
was life-changing 
	- JO: Supported Norwegian Cancer Organisation 
battling breast cancer. Launched the podcast 
“Johaug Redaksjonen” which focused on training 
and mental health.
	• 3b. eNPS: 1/100 
	- 3c. Winningtemp Temp score: 7.3/10; Winningtemp 
response rate: 76-84%
	• 3a. Engage consumers and 
people in physical activity
	• 3b. Stabilise eNPS towards 
industry level
	• 3c. Increase Winningtemp 
score by 15%
4. Human 
rights
	• 4a. T1 suppliers audited 
with BSCI or similar audit 
schemes
	• 4b. Salient human rights 
issues, qualitative progress
	• 4a & b. Active 
Brands support 
and protect human 
rights in our supply 
chain, with a focus 
on identified salient 
human rights issues
	• 4a. All vendors audited in person via BSCI in 2022: 
58% by number of vendors, 93% by volumes
	- Vendors outside Europe audited via BSCI in 2022: 
67% by number of vendors, 94% by volume
	• 4b. Developed and implemented Active Brands 
Responsible Business Conduct Policy. Updated 
materiality assessment ongoing and will continue 
during Q1 ‘23
	• 4a. 75% of Tier 1 suppliers, 
outside Europe, were audited 
with BSCI or similar audit 
schemes
	• 4b. Identifying salient human 
rights issues and developing 
an action plan and targets to 
address them
ACTIVE BRANDS’ ESG STRATEGY 2023 
Active Brands has selected the following SDGs to which it has an opportunity to contribute:
Protect labour rights and promote safe and secure working 
environments for all workers (8.8), and facilitate equal pay 
for work of equal value (8.5). Take measures to eradicate 
forced labour, end modern slavery and human trafficking, 
and secure the prohibition and elimination of the worst 
forms of child labour(8.7)
Achieve sustainable management and efficient use of 
natural resources (12.2) and reduce waste generation 
through prevention, reduction, recycling, and reuse (12.5)
Mobilise and share knowledge, expertise, technology, and 
financial resources, to support the achievement of the 
Sustainable Development Goals (17.16)
 FSN Portfolio Company since 2017
activebrands.com
Active Brands is a leading Nordic supplier of sporting goods brands 
and promotes seven own brands. The Active Brands’ product portfolio 
consists of a variety of sports apparel, and equipment related to an active 
lifestyle. Norway is currently the company’s biggest market, while Sweden 
and North America represent the second and third largest end-markets. 
Whereas the company’s main customer group is B2B (serving sporting 
goods e-tailers and retailers), the fastest growing route to market is repre-
sented by Active Brands’ own web shops.
Main raw materials include animal products like wool and goose down, 
as well as cotton and certain synthetic fabrics. Active Brands sources 
raw materials globally, and products are manufactured by third-party 
producers, most of which are found in Asia.
Active Brands’ potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS 
& SUPPLIERS 
∙	 Water depletion and pollution in 
the cotton supply chain
∙	 Water use during textile production
∙	 Local pollution from chemicals in 
textile production (e.g. dyeing)
∙	 GHG emissions and energy use in 
material production 
∙	 Animal welfare in wool and down 
production
∙	 Labour and human rights
∙	 Health and safety of workers
∙	 Socioeconomic impact of 
corruption and bribery in the 
supply chain
PRODUCT
ASSEMBLING
 
∙	 Local pollution from chemical use in 
product assembling
∙	 GHG emissions and energy use 
from product assembling
∙	 Material waste in production
∙	 Packaging waste (paper, plastic)
∙	 Labour and human rights in 
garment factories
∙	 Health and safety in garment 
factories
∙	 Work-life balance
∙	 Diversity and inclusion
MANAGEMENT  
& MARKETING
 
∙	 GHG emissions from inbound and 
outbound logistics
∙	 Energy use in sales offices and 
stores
∙	 Employee commuting and business 
travel
∙	 Office waste
∙	 Textile waste from outdated 
collections
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Social impacts of marketing 
activities (body image, 
representation)
∙	 Anti-corruption and bribery
CUSTOMERS 
& END-USERS
∙	 Microfiber pollution during the 
washing of textile products
∙	 Textile waste from used/torn 
garments
∙	 Longevity of products
∙	 Packaging waste (paper, plastic)
∙	 Product health impacts in use (e.g. 
toxins)
∙	 Contributing to sport safety
∙	 Active and healthy lifestyles
∙	 Contract conditions (B2B 
customers)
Initial EU taxonomy assessment
Key activities
∙	 C14.1 - Manufacture of wearing apparel
∙	 G46.4 - Wholesale of textiles, clothing, and footwear
External factors impacting Active Brands based on its sector, jurisdictions, 
and operations
	
+ Demand for low impact and circular products produced in socially 
sustainable ways
	
+ Active lifestyle associated with positive health outcomes 
	- Scrutiny of the environmental footprint of the textile industry
	- Climate change causing shifts in seasons, impacting consumption 
patterns and demand, and risk of causing disruption in the supply chain
	- Scrutiny of human rights and labour conditions in the supply chain
Potential contribution to environmental objective
∙	 Transition to a Circular Economy

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
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61
Access to safe, effective, quality, and affordable essential 
medicines and vaccines for all (3.8)
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Minimise the 
environmental 
impact of our 
operations
	• 1a. GHG 
emissions 
	• 1b. Energy 
consumption per 
pack
	• 1c. Responsible 
Waste mgmt
	• 1a. Net Zero GHG 
emission in production
	• 1b. Energy 
consumption p. pack 
reduced by 30%
	• 1c. 100% re-use of 
recyclable Waste 
	• 1a. Baseline scope 1 and 2 defined for 
production
	• 1b. Energy consumption baseline on group 
and site level defined 
	• 1c. Further specified responsible waste 
mgmt. as a company target
	• 1a. Create a full baseline (scope 1-3); 
Monitor and maintain baseline as 
group growths
	• 1b. Perform energy analysis on group 
level to set reduction targets  
	• 1c. Develop and implement a 
recyclable waste management 
2. Safe, 
accessible, 
and affordable 
products
	• 2a. Therapeutic 
areas
	• 2b. Number 
of countries 
supplied
	• 2c. Number of 
patients reached 
	• 2a. Number of diseases 
combated
	• 2b. Provide products to 
more than 60 countries
	• 2c. Number of patient 
reached >100m
	• 2a. Two therapeutic areas added
	• 2b. Fully operating sites during the 
COVID pandemic, despite global price 
changes.
	• 2a. Add at least three more therapeu-
tical areas
	• 2b. Two more countries to be supplied
	• 2c. At least double the number of 
patients reached 
3. Healthy, 
engaged, and 
satisfied  
employees 
	• 3a. Absenteeism 
rate 
	• 3b. Safe working 
environment
	• 3c. Female 
employee rate
	• 3d. Lost time 
incident rate 
(LTIR)
	• 3e. ESG 
resources
	• 3f.  eNPS
	• 3a. <4% absenteeism
	• 3b. Continuous review 
of EHS measures in all 
entities
	• 3c. Increased diversity 
score
	• 3d. LTIR of 0
	• 3e. ESG resource per 
site 
	• 3f. eNPS of >15%
	• 3a. Target achieved after normalisation for 
COVID protection initiatives
	• 3b. Fire Safety review with external 
experts
	• 3c. 16% increase on top governance 
level female rate, Interviewer awareness 
training to prevent Halo effect, diversity 
reporting implemented
	• 3d. Initiatives identified
	• 3e. Decision to allocate percentages to 
C-Level and on-site to HSE person
	• 3a.  <6,5% absenteeism
	• 3b.  Drive standardisation across sites
	• 3c. Keep diversity of 50% male/
female 
	• 3d. Implement initiatives to reduce 
LTIR
	• 3e. Integrate ESG resources in the 
ESG network
	• 3f. Define baseline and identify 
improvement measures
4. Ensure 
responsible 
supply chains
	• 4a. Supplier 
CoC signed by 
suppliers
	• 4b. Supplier 
audits and 
findings
	• 4a. Stakeholders able 
to trace the full supply 
chain
	• 4b. 100% of tier 1 
suppliers audited
	• 4a. Postponed due to global supply chain 
interruptions
	• 4b. Ongoing audits performed
	• 4a. Start the process with suppliers
	• 4b. Define alternate sources for three 
suppliers
5. Promote 
integrity 
throughout 
our operations
	• 5a. CoC
	• 5b. CoC training
	• 5c. Anonymous 
and electronic 
whistleblower 
channel
	• 5d. Company’s 
core values
	• 5a. 100% of employees 
sign and live by CoC
	• 5b. 100% of employees 
undergo regular 
training 
	• 5c. Whistleblower 
channel available to all 
employees
	• 5d.  Company’s core 
values as required 
part of performance 
appraisal and career 
compression 
	• 5a. CoC communicated to all employees
	• 5b. Postponed due to reprioritisation of 
resources
	• 5c. Whistleblower Channel established 
and working
	• 5d. New KPI/ target only set in 2022.
	• Significant donation of life-saving 
injectables to Ukraine
	• 5a. Roll out CoC to all new acquisi-
tions of Adragos group
	• 5b. Implement an e-learning platform 
and curriculum for all levels
	• 5c. Expand whistleblower access to 
newly acquired companies
	• 5d. Define and implement the 
company’s core values
ADRAGOS PHARMA’S ESG STRATEGY 2023 
Adragos Pharma has selected the following SDGs 
to which it has an opportunity to contribute:
Support full and productive employment and decent work for 
all, including equal pay for work of equal value (8.5)
Enhance scientific research (9.5)
Environmentally sound management of chemicals and all 
wastes throughout their life cycle, and significantly reduce 
their release to air, water, and soil (12.4)
FSN Portfolio Company since 2021
adragos-pharma.com
Adragos Pharma is a globally operating B2B Contract Development and Manufacturing 
Organisation (CDMO), headquartered in Germany. The company employs more than 
600 people, servicing primarily European, Japanese, and North American pharmaceu-
tical customers. Adragos pursues a buy and build strategy, focused on buying underuti-
lised production sites from large pharma companies, and subsequently increasing the 
utilisation, optimising the production capabilities and efficiencies of these sites.
Adragos currently operates 4 production sites in France, Germany, and Japan, 
specialised in the end-to-end production of the finished dosage form (FDF) of pharma-
ceuticals. The main business consists of non-biotech pharmaceuticals, so-called 
small molecules which constitute the vast majority of all pharmaceuticals globally. 
Exemplary dosage forms are semi-solids (such as creams and ointments), solids as well 
as sterile and non-sterile liquids. Adragos sources the main raw materials, i.e. active 
pharmaceutical ingredients and others from sources in Asia and Europe.
Adragos Pharma’s potential ESG impacts based on its sector, jurisdictions, and 
operations
Topics of higher importance in bold
RAW MATERIALS 
& SUPPLIERS 
∙	 Emissions in raw material extraction 
∙	 Hazardous waste 
∙	 Biodiversity impact of raw materials
∙	 Water use in the supply chain
∙	 Health and safety in supplier 
operations
∙	 Labour and human rights in the 
supply chain
∙	 Supply chain transparency and 
business ethics in procurement 
practices
∙	 Material certificates and supplier 
management
OWN 
OPERATIONS  
 
∙	 Hazardous waste from chemicals
∙	 Climate impact of transportation 
and logistics
∙	 GHG emissions from production 
and freezers
∙	 Sustainable packaging
∙	 Water use
∙	 Waste management and recycling 
of packaging
∙	 Health and safety at own 
production sites
∙	 Labour conditions and human 
rights at own production sites
∙	 Business ethics
MANAGEMENT  
& MARKETING
 
∙	 Business travel and employee 
commuting 
∙	 Diversity and anti-discrimination 
∙	 Employee education and 
development
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Tax policies and payments 
∙	 Whistleblowing mechanisms
CUSTOMERS 
& END-USERS
∙	 End-of-life management (recycling)
∙	 Product quality and safety
∙	 Selling practice and product 
labelling
∙	 Access to affordable products and 
medicine
∙	 Product safety, reliability and 
traceability
∙	 Contract conditions for customers
Initial EU taxonomy assessment
Key activities
∙	 C21.2 - Manufacture of pharmaceutical preparations
 
External factors impacting Adragos Pharma based on its sector, jurisdictions, 
and operations
	
+ Ageing population drives demand for safe and accessible medicines
	
+ Efficient production sites enable affordability of medicines
	
+ Strong desire to repatriate pharma-production from low-cost 
countries to secure drug supply in Western healthcare systems
	- Ever higher regulatory requirements and standards for production 
	- Increasingly complex global Supply Chain challenges for active 
ingredients with discussions on dependency from Asia
Potential contribution to environmental objective
∙	 Pollution prevention and control

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
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63
FOCUS 
AREA
KPIS
LONG TERM 
TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Climate 
efficient 
operations
	• 1a. Reduce 
GHG 
emissions
	• 1b. Internal 
car policy
	• 1c. Green 
electricity
	• 1d. Waste 
management 
	• 1a. Net Zero
	• 1b. 80% of 
company cars 
are electric or 
hybrid; electric 
car chargers in 
every location 
	• 1c. 100% 
certified green 
electricity at all 
locations 
	• 1d. 100% 
recycling of 
e-waste
	• 1a. Scope 1-3 mapped, with scopes 1 and 2 
fully measured 
	- Launch of Corporate emissions reduction 
and removal initiatives including risk 
assessment of procurement of office 
materials and provisions
	• 1b. 36% of all ecovium cars are E-autos or 
hybrids. Due to the green energy supply 
stop, no electric-charge stations were 
installed in 2022.
	• 1c. Four of eight German ecovium 
locations operate with 100% green energy. 
Conversion of two additional locations 
pre-arranged.
	• 1d. Collecting recycling boxes for private 
e-waste were placed in all ecovium GmbH 
locations.
	• 1a. Report full scope 1-3 emissions for the group 
and set Science Based Targets 
	• 1b.  Increase the quota of electric/hybrid cars in 
our fleet 
	- Pursue the installation of E-charge stations 
wherever possible among all our locations
	• 1c. Extend green electricity conversion to all 
locations
	• 1d. Resume inventory of corporate e-waste 
and establish a standard recycling model in all 
locations
2. 
Supporting 
customers’ 
sustain-
ability 
journey
	• 2a. Hours of 
software devt. 
for green 
transition 
offering
	• 2b. Hours 
of software 
devt. for 
transparency 
offering 
	• 2a. Provide 
services 
that enable 
customers to 
reduce their 
climate footprint
	• 2b. Provide 
services 
that enable 
supply chain 
transparency 
	• 2a. E-Commerce Suite was launched, 
offering three main functionalities 
for our customers’ climate footprint 
reduction: delivery address validation, 
eco-efficient route planning, and intelligent 
retour-management
	• 2b. Forwarder Suite launched with tracking 
and data sharing as main functionalities, 
which increases transparency between our 
customers and their supply chain partners
	• 2a. & 2b. Hours of development to be monitored 
for:
	- Cloud first strategy: elaboration of new products 
in collaboration with climate-neutral cloud 
providers
	- Introduction of the SimpleChain platform, which 
reduces energy consumption and data loads at the 
consumers’ end
3. Satisfied 
and 
engaged 
employees 
	• 3a. One team 
firm 
	• 3b. Diversity
	• 3c. ESG 
leadership
	• 3a. One team 
firm
	• 3b. ecovium to 
be a successful 
example of 
diversity within 
the IT field
	• 3c. ecovium 
recognised as a 
leader in ESG
	• 3a. Established a task force to address 
learnings from our employee engagement 
platform (Winningtemp)
	- 87% Winningtemp response rate for 
ecovium GmbH users. eNPS of 5
	• 3b. 50 % women in C-Level/1st 
level management, 40% in 2nd level 
management, and 15% in the R&D 
department
	• 3c. ESG considerations fully integrated into 
the company strategy until 2025 
	• 3a. Further increase Winningtemp participation 
with roll-out to MANTIS S.A.
	- One team culture: integrate MANTIS S.A. in 
culture and establish a common approach within 
the group.
	• 3b. Join 3rd party initiative focused on diversity 
(e.g. German Charta der Vielfalt) and set up a task 
force to manage diversity related activities
	• 3c. Establish an ESG working team 
	- Monitor ESG activities with special attention to 
incidents
	- Prepare to respond to EU Corporate Social 
Responsibility Directive 
4. Reliable 
services
	• 4a. Product 
security and 
reliability  
	• 4b. Data 
security and 
privacy 
	• 4a. No customer 
downtime as a 
result of product 
malfunction
	• 4b. No data 
breaches
	• 4a. Analysis of diverse tools confirms 
that a uniform measurement would not 
be possible due to mixed client support 
frameworks within the company 
	• 4b. 88% of all employees were trained in 
data protection and 70% in cyber security. 
	- Granted collaboration with an external 
Data Protection Officer to ensure quality.  
	• 4a. Define processes and start measurement 
focused on (1) Number of registered issues (2) 
service disruptions (3) total customer downtime
	• 4b. Development of learning material for 
advanced GDPR topics (e.g. systematic handling 
of data breaches) for all employees
	- Elaboration of more detailed documentation of 
technical and organisational measures to facilitate 
quality checks
5. Ethical 
business 
conduct
	• 5a. Ethics 
training and 
controls
	• 5b. Supply 
chain 
management 
	• 5a. Employees 
annually trained 
in ESG
	• 5b. Best in class 
supply chain 
management 
	• 5a. & 5b. Updated CoC, supplier CoC, 
anti-corruption, and whistleblower 
policies; rolled out to all employees
	- Introduction of the "Sustainability Days" 
	• 5a. Continuation of eLearning and training on key 
policies, including listing cybersecurity awareness 
in our new learning platform (ecovium Academy), 
to be rolled out to 100% of employees
	- Establish an electronic whistleblower system 
(iWhistle)
	• 5b. Supply chain screening for IT procurement 
- both for internal usage as for units bought for 
Hardware division, incl. signature of supplier CoC
ECOVIUM'S ESG STRATEGY 2023 
ecovium has selected the following SDGs to which it has an opportunity to contribute:
Improve education, aware-
ness-raising, and human and 
institutional capacity on climate 
change mitigation, adaptation, 
impact reduction, and early 
warning (13.3)
Achieve higher levels of economic 
productivity through technological 
upgrading (8.2) and improve global 
resource efficiency in consumption 
and production (8.4)
Upgrade technological capabilities 
of industrial sectors in all countries 
(9.5)
FSN Portfolio Company since 2020
ecovium.com
ecovium is a leading end-to-end logistics software provider that offers 
sustainable and economical solutions to its customers. Its solutions 
cover four main areas of the logistics supply chain: shipping, customs, 
warehousing, and transportation. The hardware division sells and 
configures accompanying products from the major original equipment 
manufacturers (OEMs).
Headquartered in Neustadt, Germany, the company primarily operates 
in the DACH region, Central and Southern Europe, and North America.
ecovium’s business approach combines deep expertise in the logistics 
industry with modern software development. With the add-on of Mantis, 
ecovium now counts more than 400 employees and serves a large customer 
base ranging from medium to large companies from a wide range of 
industries, including logistics forwarders, retail, e-commerce, wholesale, 
and manufacturing.
ecovium’s potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS 
& SUPPLIERS 
∙	 GHG emissions and energy use 
from the production of hardware 
and leased data centre services
∙	 Local emissions from mineral 
extraction (hardware)
∙	 E-waste and hazardous waste
∙	 Impact on biodiversity in hardware 
supply chain and at data centre 
sites
∙	 Water and cooling used in data 
centres
∙	 Labour and human rights in 
hardware production 
∙	 Workers' health and safety 
∙	 Socioeconomic impacts of conflict 
minerals
OWN
OPERATIONS
 
∙	 End-of-life management of IT 
equipment and data centres
∙	 GHG emissions and energy 
consumption from own data centre 
services
∙	 Water and cooling used in data 
centres
∙	 Impact on biodiversity and sound 
pollution from data centre sites
∙	 Employee education and  
development
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Data security and privacy
∙	 Professional integrity and honest 
advice
MANAGEMENT  
& MARKETING
 
∙	 Office waste (food waste, 
stationery)
∙	 Energy use in own offices
∙	 Employee commuting and business 
travel
∙	 Employee education and  
development
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Employee pensions
∙	 Data security and privacy
CUSTOMERS 
& END-USERS
∙	 Energy use of products and services
∙	 Impact on customers' production 
and resource efficiency
∙	 Digital literacy
∙	 Contributing to more efficient 
work management
∙	 Customer work-life balance (home 
office)
∙	 System reliability  
(lagging, downtime)
∙	 Contract conditions  
(B2B customers)
Initial EU taxonomy assessment
Key activities
∙	 J62.01 – Computer programming activities
 
External factors impacting ecovium based on its sector, jurisdictions, 
and operations
	
+ Demand for efficient and sustainable logistics solutions supporting 
the reduction in cost and climate impact
	
+ Demand for solutions that allow for tracking of emissions across the 
supply chain
	
+ Demand for solutions that facilitates supply chain transparency, 
driven by regulatory requirements
	- Heightened cyber attack risks globally, putting pressure on product 
security and system reliability
	- Scrutiny on environmental and social impacts of data centres and 
hardware
Potential contribution to environmental objective
∙	 Climate change mitigation (enabling)
∙	 Climate change adaptation

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
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65
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Engaged 
and satisfied 
employees
	• 1a. Employee satis-
faction (eNPS)
	• 1b. Overall gender 
distribution  
(% females)
	• 1c. Gender distribution 
in management  
(% female managers)
	• 1d. Gender pay gap
	• 1a. eNPS of +60
	• 1b. 50% female
	• 1c. 50% female
	• 1d. No pay gap
	• 1a. eNPS:
2021: 79
2022: 57
	• 1b. % females amongst FTEs:
2021: not measured
2022: 46.2%
	• 1c. % female managers:
2021: not measured
2022: not measured
	• 1d. Gender pay gap
2021: not measured
2022: not measured
	• 1a. eNPS target of +60
	• 1b. Female ratio target of 50%
	• 1c. Female ratio target of 25%
	• 1d. Gender pay gap target of 0
2. Services 
supporting 
sustainability 
in Life 
Sciences 
	• 2a. Customer satis-
faction (eNPS)
	• 2b. % sales on Life 
Science companies
	• 2c. % sales on specific 
ESG aspects at 
customers
	• 2a. eNPS of +40
	• 2b. +90% sales
	• 2c. 25% sales
	• 2a. eNPS:
2021: 53
2022: 49
	• 2b. % sales:
2021: 100%
2022: 100%
	• 2c. % sales:
2021: not measured
2022: not measured
	• 2a. eNPS target of +40
	• 2b. +90% sales
	• 2c. Less than 10% sales
3. Promote 
integrity 
throughout 
our operations 
	• 3a. CoC /
Whistleblower function
	• 3b. Pending whistle-
blower remediating 
actions
	• 3c. # of client ESG 
screenings
	• 3d. # of supplier ESG 
screenings 
	• 3a. CoC is periodically 
updated
	• 3b. Less than 10%
	• 3c. All new clients
	• 3d. All new suppliers
	• 3a. CoC:
2021: not existing
2022: not existing
	• 3b. Whistleblower remediating 
actions:
2021: not existing
2022: not existing
	• 3c. # of ESG screenings:
2021: not measured
2022: not measured
	• 3d. # of ESG screenings:
2021: not measured
2022: not measured
	• 3a. Institutionalise CoC
	• 3b. Less than 10%
	• 3c. All new clients
	• 3d. All new suppliers
4. Minimise 
environmental 
impact 
	• 4a. GHG emissions 
	• 4a. Reduce GHG 
emissions
	• 4a. Identified GHG emissions as 
material KPI
	• 4a.  Start to report GHG 
emissions, conduct full scope 3 
screening
EPISTA'S ESG STRATEGY 2023 
Epista has selected the following SDGs to which it has an opportunity to contribute:
Achieve universal health coverage, including financial risk 
protection, access to quality essential health-care services 
and access to safe, effective, quality and affordable essential 
medicines and vaccines for all (3.8)
Ensure women’s full and effective participation and equal 
opportunities for leadership at all levels of decision-
making in political, economic and public life (5.5) 
Enhance scientific research, upgrade the technological 
capabilities of industrial sectors in all countries, in particular 
developing countries, including, by 2030, encouraging 
innovation and substantially increasing the number of research 
and development workers per 1 million people and public and 
private research and development spending (9.5)
By 2030, achieve the sustainable management and efficient 
use of natural resources (12.2). By 2020, achieve the 
environmentally sound management of chemicals and all 
wastes throughout their life cycle, in accordance with agreed 
international frameworks, and significantly reduce their release 
to air, water and soil in order to minimise their adverse impacts 
on human health and the environment (12.4)
FSN Portfolio Company since 2022
epista.com
Epista is a life-science consultancy with a team of experts working 
at the intersection of business priorities and compliance requirements. 
Established in 2009, the company is headquartered in the life-science 
hub of Hørsholm, Denmark, and employs more than 120 people across 
Denmark, Sweden, and Germany. 
Epista is dedicated to the life-sciences industry, serving pharma, 
biotech, medical device, and CDMO customers with IT services, 
consulting, staff augmentation, and managing operations related to an 
ever-changing IT and automation landscape. The launch of the 'Cloud 
Transition' proposition in 2017, and the 'Biotech accelerator' proposition 
in 2020, propelled the company into playing a deeper role as a holistic IT 
service and managed operations partner. 
Epista's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
FACILITY &  
EQUIPMENT SUPPLY 
∙	 Local emissions from mineral 
extraction (hardware)
∙	 E-waste and hazardous waste in 
supply chain
∙	 Impact on biodiversity in hardware 
supply chain
∙	 Water and energy consumption 
for cooling in data centres
∙	 Labour and human rights in 
hardware production
∙	 Health and safety in computer 
factories and production sites
∙	 Corruption and bribery in the 
hardware production supply chain
OWN
OPERATIONS
∙	 Energy use in own offices
∙	 E-waste and end-of-life 
management of IT equipment
∙	 Employee commuting and business 
travel
∙	 Employee education and 
development
∙	 Labour conditions and human 
rights for employees
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Data security and privacy
∙	 Professional integrity and honest 
advice
MANAGEMENT  
& MARKETING
∙	 General waste management in 
offices
∙	 Increased impact through 
growth of group: due diligence 
responsibility of new acquisitions
∙	 Employee education and 
development
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Data security and privacy
∙	 Business ethics
∙	 Anti-competitive behaviour
∙	 Employee pensions
CUSTOMERS 
& END-USERS
∙	 Customers’ production and resource 
efficiency
∙	 Waste and hazardous materials 
in environment and water from 
pharmaceuticals
∙	 Drug development process
∙	 Cost of manufacturing drugs
∙	 Access and affordability of drugs
∙	 Drug product quality and safety
∙	 The ethical aspect of selling 
practices & product labelling
External factors impacting Epista based on its sector, jurisdictions, and operations
	
+ Demand for safe, affordable, and accessible drugs driven by 
globalisation and the growing and ageing population 
	
+ Increasingly regulated market drives pharma customer demand
	
+ Opportunity to differentiate as an employer by providing meaningful 
jobs
	- Risk of association with customers’ public image and reputation (e.g., 
due to cost of drugs, accessibility, safety etc.)
	- Increasing stakeholder expectations for formalisation of ESG 
strategies, actions, and results
	- Fight for talent in the industry
100
100 %
100
100

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Increase the number of youth and adults who have relevant 
skills, including technical and vocational skills, for employment, 
decent jobs, and entrepreneurship (4.4)
Achieve sustainable management and 
efficient use of natural resources (12.2)
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Accelerate 
the green 
and digital 
transition for 
our customers
	• 1a. # of Connected 
Company indexes 
performed on 
sustainability
	• 1b. Total amount 
of GHG Emissions 
we help to reduce 
	• 1a. Sustainability Services are 
fully integrated into all our 
customer offerings 
	• 1b. We can track and see a 
GHG emission reduction 
of customers through our 
services
	• 1a. Developed a Connected 
Company index linked to 
services, to assess a customer’s 
maturity level on sustainability
	• 1b. Providing customers with 
cloud services that contribute to 
reducing emissions
	• 1a. Connected Company sustainability 
indexes to be conducted by all 6 
regions with 20% of our strategic 
customers
	• 1b. Develop a tracking system for 
the GHG emission reduction for 
customers using Microsoft research 
insights to measure our impact
 2. Sustainable 
employer to 
reduce climate 
and environ-
mental impacts
	• 2a. Reduction of 
GHG emissions 
(scope 1,2 and 3)
	• 2a. Net zero GHG emissions 
by 2030
	• 2a. Reporting of Scope 1, 2 
and 3 emissions available (but 
accuracy and comprehen-
siveness need to be improved). 
Action plans in the regions to be 
put in place
	• 2a. Reporting of Scope 1, 2, 3 
emissions. Develop an Action plan for 
setting science-based targets 
3. Best 
workplace in 
the industry by 
maximising the  
engagement of 
our employees
	• 3a. eNPS
	• 3b. Psychological 
safety as key-indi-
cator D&I
	• 3c. Diversity
	• 3a. eNPS of >35
	• 3b. Psychological safety 
target of 8.0
	• 3c. Diversity in thought, 
experience, nationality, and 
orientation
	• 3a. eNPS of 26 
	• 3b. Psychological safety 7.7
	• 3c. 35% female new hires
	• 3a. eNPS of 35
	• 3b. Psychological safety target of 8.0
	• 3c. 40% female new hires
4. Enabling 
societal digital 
inclusion
	• 4a. Budget  
allocation of 
digital inclusion 
fund
	• 4a. Deliver positive social  
impacts in the regions where 
we operate by improving 
digital inclusion with our 
digital expertise and by 
funding
	• 4a. Completed selection. And 
initial talks with 4 major digital 
inclusion/skills associations 
that have a social impact in the 
regions
	• 4a. Support the 4 selected digital 
inclusion associations regionally 
through funding and measure the 
impacts
5. Ethical and 
reliable business 
partner
	• 5a. 100% 
compliance with 
data privacy and 
security policies
	• 5b. Business 
conduct 
(compliance with 
human rights, 
labour rights)
	• 5a. Protection of data and 
information of stakeholders 
we work with
	• 5b. 100% of employees 
undergo (bi)annual business 
conducts and ESG training
	• 5a & b. Green guidance has been 
developed for all regions
	• 5a & b. 100% adoption of ESG policies 
through mandatory review in our 
central e-learning portal. Development 
of Group GDPR policy in HY2
FELLOWMIND'S ESG STRATEGY 2023 
Fellowmind has selected the following SDGs to which it has an opportunity to contribute:
Support full and productive employment and 
decent work for all, including equal pay for 
work of equal value (8.5)
Improve education, awareness-raising and human and 
institutional capacity on climate change mitigation, adaptation, 
impact reduction and early warning (13.3)
FSN Portfolio Company since 2019
fellowmindcompany.com
Fellowmind is on a mission to transform its customers' digital capabilities and help 
them transition to a greener future with the help of Microsoft's cloud solutions. Their 
comprehensive range of services includes consulting and implementation across all 
Microsoft products, as well as managed services to keep your tech running smoothly.
But that's not all. Fellowmind is also dedicated to help its customers become 
connected companies, ready to expand their influence and to make a real impact 
on their business ecosystem. By embracing the vision of the connected company, 
businesses can make quick decisions, stay ahead of the competition, and create 
meaningful connections.
With a team of over 2,000 expert IT professionals spread across six European 
countries – Finland, Sweden, Denmark, The Netherlands, Germany, and Poland – 
Fellowmind is well-equipped to serve a diverse range of clients in industries such as 
manufacturing, energy, retail, and beyond. Their clients include both public institu-
tions and private companies.
Fellowmind’s potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
FACILITY &  
EQUIPMENT SUPPLY 
∙	 GHG emissions and energy use 
from the production of hardware
∙	 Lowon (hardware)
∙	 E-waste and hazardous waste
∙	 Impact on biodiversity in hardware 
supply chain and at data centres
∙	 GHG emissions and energy 
consumption from leased data 
centre services
∙	 Water and cooling used in data 
centres
∙	 Labour and human rights in 
hardware production
∙	 Workers’ health and safety
∙	 Socioeconomic impacts of conflict 
minerals, and corruption and 
bribery in the supply chain
OWN
OPERATIONS
∙	 Energy use
∙	 End-of-life management of IT 
equipment
∙	 Employee commuting and business 
travel
∙	 Employee education and 
development
∙	 Labour conditions and human 
rights for employees
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Data security and privacy
∙	 Professional integrity and honest 
advice
MANAGEMENT  
& MARKETING
 
∙	 Office waste 
∙	 Employee education and  
development
∙	 Labour conditions and human 
rights for employees
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Employee pensions
∙	 Data security and privacy
CUSTOMERS 
& END-USERS
∙	 Energy use of products and services
∙	 Impact on customers' production 
and resource efficiency
∙	 Digital literacy
∙	 Contributing to more efficient 
work management
∙	 System reliability  
(lagging, downtime)
∙	 Contract conditions  
(B2B customers)
External factors impacting Fellowmind based on its sector, jurisdictions, 
and operations
	
+ Increased demand for green IT and services that reduce and track 
customers’ environmental footprint and support the transition to a 
low carbon economy
	
+ Need for societal digital inclusion in a world moving increasingly 
online
	- Heightened cyber attack risks globally, putting pressure on data privacy 
and security measures
	- Industry characterised by lack of diverse candidates for technical jobs
Initial EU taxonomy assessment
Key activities
∙	 J62.02 – Computer consultancy activities
 
Potential contribution to environmental objective
∙	 Climate change mitigation
∙	 Climate change adaptation

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Protect workers' health and Safety in Fibo’s production sites, 
and promote an inclusive work environment
FOCUS 
AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. 
Sustainable 
Products
	• 1a. Glue/
laminate - 
formaldehyde 
reduction
	• 1b. Sustainable 
main raw 
materials (PEFC 
/ FSC %)
	• 1c. Circular 
design
	• 1a. Formaldehyde free 
products 
	• 1b. 100% PEFC/FSC 
certified
	• 1c. Circular use of 
product at end of life
	• 1a. Fibo is well below REACH threshold 
for chemicals and now testing biobased 
alternatives to  formaldehyde-based glue 
	• 1b. PEFC / FSC certified
	• 1c. Participate in “Tre på Agder,” an initiative 
to develop an industry cluster to share 
common knowledge and add value for 
business
	• 1a. Further assess identified alternative 
to formaldehyde glue
	• 1b. PEFC / FSC re-certification
	• 1c. Data collection in participating 
companies and sharing of knowledge 
to brainstorm circular solutions
2. Climate 
Impact
	• 2a. Electricity 
usage (kwh/m2)
	• 2b. % Renewable 
energy usage
	• 2c. GHG 
emissions
	• 2d. 
Environmental 
management 
system
	• 2a. 10-15% reduction
	• 2b. 95%
	• 2c. Become Net Zero
	• 2d. ISO 14001 
certification
	• 2a. Energy usage (kwh/m2) 
2022: 1.97 (-2,5%)
2021: 2.02 (-1,5%)
2020: 2.05 (-0,5%)                   
2019: 2.06 (-0,5%)
	• 2b. 93,6% (100% Green certified electricity)
	• 2c. Reported complete scope 1-3 emissions
	• 2d. Achieved ISO 14001 certification
	• 2a. Reduce energy usage by 1.5%, 
	• 2b. Identify ways to further reduce 
energy usage
	• 2c. Develop science-based targets 
together with external consultants, to 
reduce the climate footprint
	• 2d. ISO 14001 re-certification. 
Introduce organic waste fraction
3. Waste 
Manage-
ment
	• 3a. Product 
Waste (% / 
produced m2)
	• 3b. Residual 
waste (kg/m2 
produced)
	• 3a. =<4%
	• 3b. 0.029  kg/m2
	• 3a. Waste (% of produced m2)
2022: 4,49% (New raw materials)
2021: 4.17%
2020: 4.70%
2019: 5.00%
	• 3b. 2022: 0.026 kg/m2 
2021: 0,024 kg/m2 
	• 3a. Focus on process/supplier 
improvement
	• 3b. Introduce new waste fractions to 
increase recirculation 
4. Satisfied 
employees 
that are 
passionate 
about Fibo
	• 4a. Employee 
NPS
	• 4b. Turnover %
	• 4c. Sick leave %
	• 4d. Gender 
diversity
	• 4a. eNPS of 50%
	• 4b. Below 5%
	• 4c. Below 1.5% (Short 
term)
	• 4d. Increase total % 
of women, and 25% 
women in production
	• 4a. eNPS score of:
2022: 30,5
2021: 50
2020: 52
2019: 21
	• 4b. Turnover of 5.16%
	• 4c. Short term sick leave:
2022: 1.8%
2021: 1.7%
2020: 1.3%
2019: 2.2%
	• 4d. 24% Women, 21,5% in production
	• 4a. eNPS of 40
	• 4b. Turnover below 5%
	• 4c. Sick leave of 1.5% 
	• 4d. Keep current level (no new hiring 
planned) 
5. Ethical 
business 
behaviour
	• 5a. Supply chain 
management of 
all suppliers
	• 5b. Governance 
training
	• 5c. Fair working 
conditions
	• 5d. 
Whistleblower 
policy and 
channel 
	• 5a. Best in class supply 
chain mgmt.
	• 5b. All key employees 
participate in 
governance training
	• 5c. Prevent social 
dumping practice
	• 5d. Whistleblower 
channel and policy 
included in the 
HRM system, and all 
employees informed
	• 5a. Implemented Business Partner 
Management Manual (includes reporting 
procedures, CoC, and training of employees); 
Screened all suppliers in sanctions lists
	• 5b. CoC training with all new employees
	• 5c. Participation in Fair Play Agder. 
Management and union represented
	• 5d. Established through 3rd party provider. 
Included in the new HRM system
	• 5a. Further formalise and strengthen 
supply chain management. 100% of 
suppliers signed CoC.
	• 5b. Publish e-learning in the new HRM 
system
	• 5c. Continue membership in Fair Play 
Agder Working/salary conditions 
included in CoC signed by suppliers
	• 5d. Regular information to all 
employees through Simployer
FIBO'S ESG STRATEGY 2023 
Fibo has selected the following SDGs to which it has an opportunity to contribute:
Increase resource efficiency in own production processes by
adapting clean and environmentally sound technologies
Contribute to sustainable forest management through 
cooperation with raw material suppliers
Reduce resource consumption by developing circular product 
attributes and minimising waste in the production process
2.50 %
6.00 %
100%
2.5%
FSN Portfolio Company since 2015
fibo.no
Fibo is the leading global manufacturer of high-quality wet room wall systems, 
which aims to be an environmentally friendly, design versatile, functional, and 
cost-efficient substitute to traditional ceramic tiles. The product range includes 
complete wet room wall systems, comprising fully waterproof wall panels and 
related installation accessories, in addition to kitchen boards and countertops.
Plywood and laminate constitute the main raw materials and are sourced from 
suppliers in Asia, Latin America, and Europe, while the end-product is produced at 
Fibo’s factory in Lyngdal, Norway.  The company is headquartered in Oslo.
The final products are sold to customers across new construction, renovation, 
and prefab housing markets across Europe and North America. Fibo is active across 
different distribution channels, with key customers being builders’ merchants, DIY 
chains, and direct B2B sales, that in turn mainly sell to installers within residential 
and non-residential construction.
Fibo’s potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 Energy consumption and emissions 
in raw material extraction
∙	 Hazardous waste from chemical use
∙	 Biodiversity impact from raw 
material sourcing and around 
production sites
∙	 GHG emissions from the 
production of materials such as 
plywood
∙	 Labour and human rights
∙	 Workers’ health and safety
∙	 Local community engagement and 
job creation
∙	 Material certificates and supplier 
management
∙	 Supply chain transparency
OWN
OPERATIONS
∙	 Climate impact from production 
(energy use, fuel type)
∙	 Climate impact of transport 
∙	 Industrial chemical handling, 
storage, and treatment
∙	 Resource efficiency and waste 
management
∙	 Chemicals used in production (e.g., 
glue)
∙	 Labour and human rights
∙	 Workers’ health and safety
∙	 Work-life balance
∙	 Business ethics
MANAGEMENT  
& MARKETING
 
∙	 Sustainable and circular design and 
packaging
∙	 Working conditions and culture
∙	 Diversity and inclusion
∙	 Local community engagement and 
job creation
∙	 Anti-corruption and integrity
∙	 Anti-competitive behaviour 
reporting
∙	 Whistleblowing mechanisms
CUSTOMERS 
& END-USERS
∙	 Product longevity
∙	 Product take-back, recycling, and 
reuse
∙	 Climate impact of shipping and 
delivery
∙	 Product quality and safety 
∙	 Selling practices and product 
labelling
∙	 Contract conditions for customers
External factors impacting Fibo based on its sector, jurisdictions, and operations
	
+ Demand for affordable, alternative products with lower GHG 
footprint as a means for climate change mitigation
	
+ Demand for products produced in socially sustainable ways, with 
HSE practices and fair wages
	- Concerns for biodiversity and climate impact of sourcing trees
	- Immature market for reuse and recycling at the end of life of products
Initial EU taxonomy assessment
Key activities
∙	 C16.21 - Manufacture of veneer sheets and wood-based panels
Potential contribution to environmental objective
∙	 Climate change mitigation (enabling)
∙	 Climate change adaptation

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71
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Environmen-
tally sound 
operations
	• 1a. Reduce GHG 
emissions
	• 1b. Waste 
management
	• 1c. Route planning
	• 1a. Roadmap for Net Zero
	• 1b. Increase waste sorting 
rate by 50%
	• 1c. Reduce transport related 
GHG emissions by 50%
	• 1a. Preparing for GHG reporting in 
the online portal
	• 1b. Assessed current procedures
	• 1c. Kicked off planning project
	• 1a. Map GHG footprint, scope 1-3
	• 1b. Implement waste 
management procedures on a 
group level
	• 1c. Establish and implement 
route planning routines for 
technicians and fitters
2. Ethical & 
transparent 
business 
conduct
	• 2a. Supply Chain 
CoC to be signed by 
main partners
	• 2b. Supply chain  
Audit
	• 2c. ESG policy 
implementation
	• 2d. Whistleblower 
channel
	• 2a. Top 100 (90%+ of 
volume) suppliers having 
signed Supply Chain CoC
	•  2b. 10 % of suppliers 
audited in person yearly
	• 2c. Annual training in ESG 
topics for all employees
	• 2d. Whistleblower channel 
familiar to 100% of 
employees
	• 2a. Supply Chain Policy adopted by 
BoD
	• 2b. Implement the supply chain 
management system; identify 
suppliers to be audited in person and 
start the audit
	• 2c. ESG policies adopted by BoD
	• 2d. Completed set-up of whistle-
blower channel
	• 2a. Top 25 suppliers to sign 
Supply Chain CoC
	• 2b. Top 10 suppliers audited in 
person
	• 2c. Anti-bribery and-corruption 
training (all relevant empl); CoC 
training and CoC commitment 
(100% empl)
	• 2d. Implement and introduce 
whistleblowing policy and 
follow-up structures
3. Motivated 
and committed 
employees
	• 3a. eNPS 
	• 3b. Engagement 
Index
	•  3c. Leadership 
Index
	• 3a. eNPS of 25
	• 3b. Engagement Index of 90
	• 3c. Leadership Index of 85
	• Brilliant Insight results* 
	• 3a. eNPS of 7
	• 3b. Engagement Index of NO 80/ 
SE 76
	• 3c. Leadership Index of  NO 75/SE 70
	• 3a. Introduce Brilliant Insights in 
all countries for measuring KPI's 
(eNPS, EI and LI)
	• 3b. Focus on internal commu-
nication; Improve day-to-day 
digital tools for employees
	• 3c. Implement basic leadership 
training
4. Promote 
equality & 
diversity
	• 4a. Share of female 
employees
	• 4b. Compensation 
and benefit policy
	• 4a. 25% female FTE’s
	• 4b. Gender equality in 
compensation and benefit 
structure
	• 4a. 10% female FTE’s
	• 4b. Identified gender inequalities as 
a focus area
	• 4a. Promote diversity in job ads; 
establish recruitment policy 
	• 4b. Implement compensation 
and benefits policy, including 
principles of equal pay for work 
of equal value 
 
* SE= Firesafe Sweden, NO= Firesafe Norway
FIRESAFE'S ESG STRATEGY 2023 
Firesafe has selected the following SDGs to which it has an opportunity to contribute:
Ensure women’s full and effective participation and equal 
opportunities for leadership (5.5)
Ensure decent working conditions in the supply chain (8.8) 
and contribute toward employment
and decent work for all (8.5)
Environmentally sound management of chemicals and all 
wastes throughout their life cycle, and significantly reduce 
their release to air, water and soil (12.4)
Firesafe’s services are a direct contribution to ensuring 
access to safe housing (11.1)
FSN Portfolio Company since 2022  
firesafe.com
Firesafe, established in 1981, is a leading Nordic supplier of fire protection 
services, including fire engineering, consulting, passive fire protection 
systems, and fire technical control and service. The range of services also 
includes fire safety training courses, and specialised solutions such as 
water mist and gas extinguishing systems, emergency lighting, escape path 
lighting systems, sprinkler systems, fire detection, and alarm systems. 
The group has a strong local presence across the Nordics with close to 
1000 employees in more than 30 locations in Norway, Sweden, Denmark, 
and Finland.
Firesafe contributes to a safer society by providing professional and 
sustainable fire protection solutions, and mainly serves the B2B segment, 
including building contractors, municipalities, housing associations, and 
real estate owners. Firesafe also develops special products and solutions 
for the offshore and marine industry.
Firesafe's potential ESG impacts based on its sector, jurisdictions, and operations
RAW MATERIALS
& SUPPLIERS 
∙	 Pollution and emissions generated 
by raw material extraction
∙	 Human rights and labour conditions 
across the raw materials supply 
chain
PRODUCTION 
∙	 PFAS still used in some fire 
extinguishers
∙	 Deep-tier Asian suppliers have 
lower E&S impact regulation 
MANAGEMENT  
& MARKETING
 
∙	 Sustainable product innovation and 
circular design
∙	 Employee well-being and company 
culture
∙	 Employee and board diversity
CUSTOMERS 
& END-USERS
∙	 Product sustainability and non-
toxicity
∙	 Refilling and recycling
∙	 Climate impact of logistics 
operations
∙	 Labelling and product safety 
External factors impacting Firesafe based on its sector, jurisdictions, 
and operations
	
+ Demand for fire safety equipment and related consulting activities 
brought about by the impacts of global warming and climate change
	
+ Demand for more climate-friendly and circular products
	- Public and consumer concern over the use of toxins, products’ wider 
contribution to climate change and emission footprint as well as the 
recyclability of products 
	- Immature market for reuse and recycling at end of life of products
Initial EU taxonomy assessment
Key activities
∙	 43.29 - Other construction installation
Potential contribution to environmental objective
∙	 Climate change mitigation
∙	 Transition to a circular economy

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
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73
PEOPLE  - We 
prioritise creating 
an inclusive and safe 
working environment 
accessible to all, 
where we encourage 
our employees to 
be innovative and 
creatively impact our 
business future
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Supporting 
customers to 
reach their
environ-
mental 
ambitions
	• 1a. Circular 
solutions 
	• 1b. Energy-
efficient 
equipment/ 
service 
	• 1c. 
Collaboration 
to reach 
climate targets
	• 1a. Partner with 
our customers and 
suppliers to develop 
circular solutions w/a 
focus on waste in the 
ice cream production
	• 1b. Be the preferred 
partner for 
sustainable solutions
	• 1c. ESG collaboration 
with suppliers, 
industry peers, and 
customers
	• 1a. High-level roadmap for 
circularity focusing on food 
waste has been defined
	• 1b. R&D improved the energy 
efficiency of the equipment
	• 1c. We have had an active role 
at the external Ice Cream Tech 
2022 conference on ESG matters. 
We have identified venues 
to collaborate on sustainable 
solutions
	• 1a. Establish a market-driven baseline for food 
waste in standard tier 1 product lines and develop 
targets for future food waste optimised equipment, 
to be included in the 2026 strategy. Actual projects 
to initiate food waste reductions will be established
	• 1b. Establish a market-driven baseline for energy 
efficiency in standard tier 1 product lines and 
develop targets for future energy efficiency 
optimised equipment, to be included in the 2026 
strategy.
	- Plan for the development of an additional product 
line with low GWP (global warming potential) 
refrigerants
	• 1c. Develop an end-of-life guide for our equipment
2. Reducing 
our 
environ-
mental 
footprint
	• 2a. ESG 
leadership  
	• 2b. Reduce 
GHG 
emissions
	• 2c. Zero waste   
	• 2a. Gram identified as 
an ESG leader in the 
ice cream industry.
	• 2b. Net Zero
	• 2c. Zero waste to 
landfill
	• 2a. Full-time ESG business 
partner was hired in May 2022. 
More than 50% of our employees 
participated in one or more ESG 
workshops and an ESG idea Bank 
was established
	• 2b. GHG reporting competencies 
strengthened through two 
key employees completing the 
UN Global Compact Climate 
Ambition Accelerator program. 
GHG emissions reductions 
initiated at several sites
	• 2c. New legal guidelines for 
waste sorting implemented in DK 
	• 2a. Integrate ESG into our 2026 Strategy, also in a 
combined focus with innovation. Conduct EcoVadis 
rating of Gram Equipment
	- Six internal ESG training and knowledge-sharing 
workshops to be facilitated on team/department 
level to boost the integration of ESG in the core 
activities
	• 2b. Establish a baseline for GHG emissions in all 
relevant scope 3 categories, to complete a full base 
year for setting SBT in 2024
	- Develop infrastructure and procedures for stream-
lined GHG reporting
	• 2c. Residual waste reduction by 20% at our biggest 
production site (DK) and optimised set-up for waste 
sorting to be implemented at all sites
3.  Motivated 
employees in 
a diverse and 
inclusive
workplace
	• 3a. eNPS 
	• 3b. Diversity 
	• 3c. Personal 
development 
	• 3a. eNPS of +40% 
	• 3b. Female new hires 
25% 
	• 3c. Regular personal 
development 
offerings to all 
employees 
	• 3a. eNPS +15% on average. Great 
variations between groups and 
therefore focus to bring the low 
scores up. We increased the 
immediate manager score to a 
satisfactory level
	• 3b. Female new hires reached 
26% and exceeded the target
	• 3c. Leadership training program 
conducted. Forty leaders 
finalised exams – all business-rel-
evant cases presented to Group 
Management
	• 3a. eNPS of +22% ​
	- Increase the immediate superior evaluation:  ​
2022: 5.73/7 ​
2023: 5.85/7​
	• 3b. Female new hires 22%. Target lower than 2022 
result but another mix in planned FTE budget. 
We will continue to focus on diversity in all 
recruitments
	• 3c. 90% of people managers/leaders have finalised 
the basic Leadership Program
4. Ethical 
value chain 
	• 4a. Supply 
chain 
management 
	• 4b. Supplier 
CoC
	• 4c. Ethical 
business 
conduct 
	• 4a. Best in class 
Supply chain 
management  
	• 4b. SCoC signed 
by all main/ key 
suppliers  
	• 4c. Annual 
ESGTraining for all 
employees 
	• 4a. Supplier risk assessment 
set-up prepared for execution 
in 2023
	• 4b. SCoC improved and a new 
version was published. 84% of 
2022 spent covered by signed 
SCoC
	• 4c. New employees' ethical 
training program developed for 
roll-out in 2023
	• 4a. Risk assessment and supplier rating through 
EcoVadis
	- ESG on the agenda for supplier conference: inform 
about our strategy and supplier expectations
	• 4b. 90% of 2023 spending covered by signed SCoC
	• 4c. 100% of employees to finalise the ethical 
training program
GRAM'S ESG STRATEGY 2023 
Gram has selected the following SDGs to which it has an opportunity to contribute:
ENVIRONMENT - 
Across operations 
and the value chain, 
we continuously 
strive to learn and 
implement new 
methods of reducing 
our environmental 
footprint concerning 
water, waste, and GHG 
emissions
GOVERNANCE - We 
adhere to responsible 
policies, practices, rules, 
and norms and fully 
support the principles 
for responsible business 
conduct laid down by 
the UN Global Compact
CIRCULARITY - We 
partner with our 
customers and 
suppliers to develop 
circular solutions 
focusing on reducing 
waste in ice cream 
production 
FSN Portfolio Company since 2018
gram-Equipment.com
Gram Equipment (Gram) designs and assembles food processing 
equipment and spare parts for the global ice cream production 
industry. The machinery is mainly for high-throughput production 
and can produce more than 40,000 ice creams per hour.
The machine parts are mainly made of stainless steel components, 
sourced from European, US, and Turkish sub-suppliers, which are 
then assembled in Gram’s facilities in Denmark and Turkey. 
Gram’s customers operate across the globe, ranging from North 
America to New Zealand. Transport to the customer is outsourced, 
while Gram handles the installation and machinery service.
Gram’s potential ESG impacts based on its sector, jurisdictions, and operations
RAW MATERIALS
& SUPPLIERS 
∙	 GHG emission reductions in scope 
3
∙	 Protection of ecosystems & 
biodiversity that can be impacted 
by operations
∙	 Health and safety in the value chain 
(suppliers' employees)
∙	 Diversity and anti-discrimination​ in 
the value chain
∙	 Labour conditions and human 
rights in the value chain
OWN
OPERATIONS
∙	 GHG emission reductions in scope 
1 and 2
∙	 Waste minimisation and prevention
∙	 Health and safety and a good 
working environment of global 
employees
∙	 Diversity and anti-discrimination​ 
∙	 Labour conditions and human 
rights
MANAGEMENT  
& MARKETING
 
∙	 Responsible supply chain practices
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Tax payment transparency
CUSTOMERS 
& END-USERS
∙	 Meeting obligations for supporting 
decarbonization of the ice cream 
business, by developing equipment 
and services that reduces food 
waste, energy use and use of high 
GWP refrigerants
∙	 Responsible End-of-life practices: 
repair, recycling​
∙	 Health and safety in the value chain 
(customers' employees who operate 
Gram equipment)
∙	 Food safety of Gram equipment
External factors impacting Gram based on its sector, jurisdictions, and operations
	
+ Managing transition and physical impact risks and 
opportunities, including the decarbonization of value chain
	
+ Ensuring access to critical talent and human capital
	
+ Enabling digitally-based global growth as substitution  of  
growth based on travel activities
	- Managing critical safety and security risks across operations
	- Geopolitical uncertainty, conflicts, and crises in the countriesGram 
operate
	- Managing compliance risks across operations
	- Responsible sourcing of critical input materials with few or no available 
substitutes, many of which are sourced from deposits concentrated in 
only a few countries
Initial EU taxonomy assessment
Key activities
∙	 C28.93 – Manufacture of machinery for food, beverage and tobacco 
processing
Potential contribution to environmental objective
∙	 Transition to a Circular Economy

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
74
75
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. We care for 
each other 
and aim to be 
an attractive 
employer who 
takes social 
responsibility 
	• 1a. Share of 
apprentices 
	• 1b. eNPS
	• 1c. Lost time injury 
frequency rate 
(LTIFR) (entity 
build up)
	• 1d. HG Academy* 
	• 1a. 12%
	• 1b. eNPS of 55, WT 
implemented in all 
companies*
	• 1c. To be defined in 2022
	• 1d. On average 20% of 
the craftsman workforce 
receive training of more 
than 3 hours/ year.  
	• 1a. 9.2%
	• 1b. Implemented Winnningtemp (WT) 
in 43% of all companies and 1 617 users. 
eNPS of 46
	• 1c. Implemented HSE / QA system in 11 
companies 
	• 1d. 342 employees completed training in 
the HG Academy**
	• 1a. 10%
	• 1b. WT implemented in 75% of 
companies*****, eNPS of 55
	• 1c. Establish monthly 
measurement for LTIFR by 
03/2023 and define targets for 
2024 + 2030
1d. 700 employees complete 
training for at least one course 
at HG Academy***
2. We shall 
understand the 
environmental 
impact of our 
business and 
strive towards 
limiting our 
environmental 
footprint 
and promote 
a circular 
economy
	• 2a. GHG emissions
	• 2b. Miljøfyrtårn / 
ISO 14001
	• 2c. CO2 emission 
saved due to HG 
solutions/advice
	• 2a. Net zero
	• 2b. 100% of companies 
being certified*
	• 2c. Tool to advice  
customers to select more 
sustainable solutions by 
2026
	• 2a. Mapped scope 1 and 2
	• 2b. Certified 16 companies
	• % certified companies:
2022: 50%
2021: 40%
2020: 33%  
	• 2c. Renewed 3 000 sqm of floors, saving 
the environment 2 000 kg of CO2 
emissions*** 
	• 2a. Identify the top two areas 
with the most significant 
impact and set science-based 
targets for 2024
	• 2b. 100% of companies being 
certified*
	• 2c. Renew 30 000 sqm of 
floors, saving 20 tons of CO2 
emissions****
3. We govern 
our business in a 
responsible way 
	• 3a. Continuous 
improvement 
of supply chain 
management
	• 3b. ESG training for 
employees 
	• 3c. Collaborations 
with organisations 
with a positive 
impact on the ESG 
factors
	• 3a. To be defined
	• 3b. 100% of employees 
undergo regular ESG 
training
	• 3c. Collaboration with 10 
organisations 
	• 3a. Established process for receiving 
suppliers’ signature on CoC
	• 3b. 75% of employees completed CoC 
eLearning
	• 3c. Three collaborations with organ-
isations, whereof two are promoting 
employment and decent work conditions
	• 3a. 100% of existing suppliers 
signed HG’s Code of 
Conduct*** 
	• 3b. 100% of new hires 
complete CoC training*****
	• 3c. Add two relevant industry 
collaborations 
*For all OpCo’s closed by 12/2022.
**HG Academy is HG’s own education institution. The purpose of the HG Academy is to provide an arena for personal development and comprise of the following modules; 
culture, leadership, project management, and expertise matters. Target excludes CoC training mandatory for all employees 
*** Materiality threshold
**** Dr Schutz Nordic A/S, compared in FIGR where polishing and waxing are used over a period of 10 years  
***** For OpCo’s closed by H1 2023
HG'S ESG STRATEGY 2023 
HG has selected the following SDGs to which it has an opportunity to contribute:
100 %
Promote sustainable consumption through waste reduction 
(12.5) and support sustainable public procurement (12.7)
Multi-stakeholder partnerships to support the achievement of 
sustainable development goals (17.16)
Reduce the number of unemployed youth through appren-
ticeship (8.6) as well as prevent shadow work and promote 
labour rights and safe working environments (8.8)
Increase the number of youth and adults who have relevant 
vocational skills for future employment by employing 
apprentices and supporting them on the way to certification 
(4.4)
                  FSN Portfolio Company since 2020
handverksgruppen.com
Håndverksgruppen (HG) is the Nordic’s largest provider of surface treatment 
services including painting, flooring, tiling, and masonry. The group has a 
strong local presence across the Nordics withmore than 3000 employees in 
over 100 operating companies.
The main input factors to offer surface treatment services are labour and 
building materials, including paint, fillers, and flooring (wood, carpets and 
epoxy). The materials are purchased mainly from large Nordic distributors 
which source the materials from leading national and international building 
materials suppliers. HG’s use of subcontractors is limited.
HG mainly serves the B2B segment, including building contractors, 
insurance companies, municipalities, and real estate owners. HG’s key value 
proposition to public and professional B2B customers is its strong ESG focus 
by offering high quality services, with clear ethical standards and strong HSE 
compliance and documentation.
HG’s potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 Chemical use in paint production
∙	 GHG emissions from the 
production and transportation of 
rehabilitation materials (carpets, 
paint, wooden floors etc.)
∙	 Hazardous waste from the 
production of materials
∙	 Labour conditions and human 
rights in raw material production
∙	 Workers' health and safety in the 
supply chain
∙	 Supply chain transparency
∙	 Business ethics in procurement
OWN
OPERATIONS
∙	 GHG emissions from transportation 
∙	 Release of hazardous substances 
occurring during rehabilitation 
activities
∙	 Waste management at  
rehabilitation sites
∙	 Material utilisation and recycling
∙	 Health and safety of own 
employees
∙	 Labour rights
∙	 Local job creation 
MANAGEMENT  
& MARKETING
 
∙	 Energy use in admin offices
∙	 Waste management in admin offices
∙	 Diversity, inclusion, and  
anti-discrimination
∙	 Employee education and 
development
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
CUSTOMERS 
& END-USERS
∙	 Ease of maintenance and repair
∙	 End of life product management 
(reuse, repair, recycling) 
∙	 Product reliability and quality
∙	 Long-term health impacts of  
toxic materials
∙	 Partner and customer integrity
External factors impacting HG based on its sector, jurisdictions, and operations
	
+ Increased demand for sustainable rehabilitation and repairs, as well 
as climate resilient solutions, taking into account material selection 
and circularity
	
+ Demand for treatment services delivered in socially sustainable ways, 
with HSE practices and fair wages
	
+ Positive momentum on biobased products (e.g., water-based paint), 
and requirements on zero-emission construction zones
	- Part of the industry has issues with regards to short term employment, 
unlawful payments, and lack of HSE practices
	- Current regulations are not promoting widespread adoption  of circular 
solutions (i.e., reuse of materials) 
Initial EU taxonomy assessment
Key activities
∙	 F43.34 – Painting and glazing
 
Potential contribution to environmental objective
∙	 Climate change mitigation (enabling)

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
76
77
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Saving lives 
and minimising 
damages during 
transport and 
traffic through 
innovation and  
zero-defect  
products
	• 1a. Zero field failures
	• 1b. Product 
development that 
improves child car 
seat safety
	• 1c. Quality and 
environmental 
performance 
certifications
	• 1a. Zero field failures
	• 1b. Continuous R&D to 
improve safety features
	• 1c. Maintain relevant 
certifications 
	• 1a. Zero field failures in 2022
	• 1b. Roll-out of Digital Safety executed 
during 2022, further product enhance-
ments implemented, and ongoing
	• 1c. Obtained IATF 16949, ISO 9001, and 
ISO 14001 certifications where applicable
	• 1a. Zero field failures
	• 1b. Roll-out of Digital Safety 
product
	• 1c. Maintain relevant 
certifications
2. Moving 
towards 
circularity and 
low-impact  
products
	• 2a. To increase the 
use of recycled 
material and reduce 
waste
	• 2b. Reduce GHG 
emissions
	• 2a. Product offering with 
recycled material
	• 2b. Net Zero
	• 2a. Discussion with supplier on the use of 
recycled plastics ongoing
	• 2b. Reported scope 1 and 2 emissions; 
initial reporting of scope 3 screening; to 
be further developed
	• 2a. Evaluate increased use 
of recycled material and 
recycling of scrap
	• 2b. Create full baseline 
emissions for scope 1-3; set 
reduction targets and create an 
action plan for reduction 
3. Commitment 
to our employees
	• 3a. Reduced 
absenteeism
	• 3b. eNPS
	• 3a. Reduced absenteeism
	• 3b. Improved eNPS for 
selected categories of 
employees
	• 3a. Marginal improvement of absen-
teeism by 0.2 pp to 5.2%
	• 3b. Improved eNPS at two European 
sites. eNPS declined at Chinese sites, 
where a significant reduction in manning 
has been executed at the time of the 
survey
	• 3a & b. Continue to improve 
working conditions by 
upgrading facilities and 
machinery. Improve eNPS by 5 
p.p. from 2022
4. Ethical busi-
ness conduct
	• 4a. Ethics training & 
controls
	• 4a. Employees annually 
trained in ESG
	• 4a. All new permanent employees signed 
CoC. Whistleblower channel is accessible 
to all employees. New versions of CoC 
and Whistleblower policies approved by 
the BoD
	• 4a. Implement CoC e-learning 
and in-person training 
material for employees
5. Responsible 
supply chain  
management
	• 5a. Number of 
supplier audits 
performed
	• 5b. Share of 
suppliers who 
signed Supplier CoC
	• 5a & b. To strengthen 
supply chain 
management to monitor 
and control risk
	• 5a. 30 supplier audits performed in 2022, 
Covid restrictions in China continue to 
limit supplier visits
	• 5b. 67% of suppliers signed Supplier CoC
	• 5a. Perform 25 supplier audits 
in 2023
	• 5b. Achieve >75% of suppliers 
signed Supplier CoC
HOLMBERGS' ESG STRATEGY 2023 
Holmbergs has selected the following SDGs to which it has an opportunity to contribute:
Develop and manufacture products that save lives. 
Invest in the health and well-being of the staff
Develop and manufacture products that are safe, developed 
in a sustainable way by reducing waste and emissions
Promote a long-term safe and secure working environment 
Develop and manufacture products for 
sustainable transports that save lives
Invests in R&D and new product development
FSN Portfolio Company since 2017
holmbergsgroup.com
Holmbergs develops and produces critical safety components and 
systems for child safety car seats, with a vision to make transport safer 
for everyone. The products include harness systems, ISOFIX connectors, 
retractors, and covers. Holmbergs works closely with today’s leading 
brands and carriers to enable it to create products that increase safety, 
comfort, and peace of mind.
The company serves B2B customers globally, primarily child seat 
OEMs (original equipment manufacturers). It also provides customers in 
other transportation niches with safety belt solutions, including buses, 
agriculture machinery, and rescue vehicles.
The company operates four production sites: two in China, one in 
Lithuania, and one in Romania. The main raw material inputs are plastic, 
metal, webbing, and textiles.
Holmbergs’ potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 GHG emissions and energy use 
from plastic, metal, and textile 
production
∙	 Biodiversity impact of raw material 
sourcing (metal, plastic, textile) and 
production sites
∙	 Water use and waste in plastic, 
metal, and webbing/textiles 
production
∙	 Hazardous waste from chemicals
∙	 Labour and human rights in 
production and sourcing
∙	 Workers’ health and safety
∙	 Socioeconomic impact of 
corruption and bribery in the 
supply chain
OWN
OPERATIONS
∙	 Energy use in own production
∙	 Emissions from in- and outbound 
logistics
∙	 Biodiversity impact of production 
sites
∙	 Water use and waste
∙	 Hazardous waste
∙	 Labour conditions and human 
rights for employees in factories 
and production sites
∙	 Workers’ health and safety
∙	 Socioeconomic impact of 
corruption and bribery in the 
supply chain
MANAGEMENT  
& MARKETING
 
∙	 Office waste
∙	 Energy use in offices
∙	 Employee and business travel
∙	 Employee education and 
development
∙	 Diversity and inclusion
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Tax policies and payments
CUSTOMERS 
& END-USERS
∙	 Product durability
∙	 Waste from used/torn products
∙	 End-of-life management (recycling 
of metal, fabric, and plastic)
∙	 Traffic safety
∙	 Product safety and user 
information
∙	 Access and affordability
∙	 Contract conditions (B2B 
customers)
∙	 Data privacy and security of 
customer data
External factors impacting Holmbergs based on its sector, jurisdictions, 
and operations
	
+  Demand for high-quality and innovative products that increase 
safety on the road
	
+ Demand for low-impact and circular products produced in socially 
sustainable ways, with fair wages and HSE practices
	- Scrutiny of the environmental impact of raw materials and end-of-life 
management of products
	- High anti-corruption and bribery risks in key markets (e.g., China)
	- Human and labour rights concerns in high-risk locations (e.g., China) 
Initial EU taxonomy assessment
Key activities
∙	 C32.99 Other industrial production not elsewhere specified
 
Potential contribution to environmental objective
∙	 Transition to a Circular Economy

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
78
79
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Enable climate 
resilience in 
society 
	• 1a. UV penetration 
of pipe rehabilitation 
worldwide 
	• 1b. Amount of CO2 
saved by using UV 
vs felt
	• 1a. Achieve EU standards 
worldwide of approx. 
80% penetration
	• 1b. Target to be 
established
	• 1a. EMEA at 80%, USA 10%, APAC at 
50%
	• 1b. Started to quantify benefits of UV 
versus felt, but data was not reliable, 
to-be-continued
	• 1a. Continue market 
penetration, keep EMEA level, 
USA 12%, APAC 53%
	• 1b. Quantify the benefits of UV 
vs felt and communicate CO2 
savings to customers. Finalise 
the assessment and use it for 
marketing
2. Minimise 
environmental 
impact of our 
operations
	• 2a. Carbon 
emissions
	• 2b. Waste as a 
percentage of 
products produced
	• 2a. Net Zero
	• 2b. Annual reduction of 
2-5% YoY
	• 2a. Track GHG emissions scope 1-2 (3) to 
assess baseline
	• 2b. Achieved approx. 65% cardboard 
box applications for EMEA liners up to 
DN400, selected new ERP system that 
will enable waste assessment in EMEA 
2023
	• 2a. Extend baseline to scope 3 
and assess reduction opportu-
nities, and reduce scope 1 and 
2 by 10%
	• 2b. Establish a waste tracking 
tool in EMEA production and 
start reducing
3. Ensure 
healthy, safe, 
and satisfied 
employees
	• 3a. LTIR (Long 
Term Incident rate) 
	• 3b. eNPS
	• 3c. Attrition
	• 3d. ESG leadership
	• 3a. LTIR of ≤ 3,6
	• 3b. eNPS of > 20
	• 3c. Annual attrition of 
<15%
	• 3d. Dedicated resources 
working on ESG
	• 3a. LTA established, resources dedicated, 
continuous improvement measures in 
place
	• 3b. Positive eNPS trend ´22 (´21) across 
regions*: USA +8 (-17), EMEA 28 (10), 
APAC 46 (15)
	• 3c. Attrition rate of 6.8%
	• 3d. Job ad posted, and applicants 
assessed
	• 3a. Reduce regional LTA by 
20%, LTIRGroup ≤ 4,5
	• 3b. Include all colleagues and 
achieve eNPS of > 20
	• 3c. Attrition of < 10%
	• 3d. Onboard a dedicated ESG 
manager and develop impact 
focused value creation plan. 
Establish an external commu-
nication campaign
4. Ensure ethical 
supply chain
	• 4a. % of 
procurement value 
sourced regionally
	• 4b. Supply chain 
code of conduct 
(sCoC)
	• 4a. > 50% of procurement 
value sourced regionally
	• 4b. 100 % of material 
supply volume signed 
sCoC
	• 4a. Identified the need to increase 
regional sourcing
	• 4b. sCoC established and dispatched, 0% 
signed
	• 4a. Source > 30% of 
procurement values regionally
	• 4b. 80% of supply volume to 
sign sCoC
5. Promote 
integrity 
throughout our 
operations
	• 5a. ESG awareness 
amongst employees
	• 5b. Whistleblower 
scheme known to all 
employees
	• 5a. 100% of employees 
trained annually in ESG 
topics 
	• 5b. 100% employees 
know the whistleblower 
scheme
	• 5a. Training was based on individual 
approaches, missing corporate approach
	• 5b. Whistleblower scheme established
	• 5a. Deploy corporate ESG 
information campaign and 
training, 95% of staff trained 
during 2023
	• 5b. Whistleblower scheme 
available and known to all 
employees and suppliers
* white collar workers only
IMPREG'S ESG STRATEGY 2023 
IMPREG has selected the following SDGs to which it has an opportunity to contribute:
Reduce the number of deaths and illnesses from hazardous 
chemicals and air, water, and soil pollution and contamination 
(3.9)
Environmentally sound management of chemicals and all 
wastes, and significantly reduce their release to air, water, and 
soil (12.4)
Improve water quality by minimising the release of hazardous 
chemicals and materials (6.3)
Upgrade infrastructure and retrofit industries to make them 
sustainable (9.4)
Protect labour rights and promote safe and secure working 
environments for all workers (8.8)
FSN Portfolio Company since 2019
impreg-group.com
IMPREG is the global manufacturing leader of fiberglass reinforced liners for 
trenchless pipe rehabilitation, sustainable cured-in-place-pipe (CIPP) waste-
water & stormwater infrastructure solutions. The company is headquartered in 
Germany and operates three dedicated manufacturing sites in Germany, China, 
and the US, with local management, production, and sales teams in each site. To 
be close to regional markets, IMPREG also operates three distribution centres in 
Australia, the UK, and the US.
Key raw material inputs include fiberglass and styrene-based resin. Along 
with the local production strategy, IMPREG focuses on localising its supply 
chain and has established relationships with local partners in Europe and China. 
The main customers are installers and contractors that conduct rehabilitation 
work for pipe owners, including municipalities. The customer base spans across 
Europe, the Middle East and Africa, Asia-Pacific, and the Americas.
IMPREG's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 GHG emissions and energy 
consumption in raw material 
production (styrene, fiberglass, 
foil)
∙	 Chemical use and hazardous waste
∙	 Labour conditions and human 
rights in the supply chain
∙	 Workers’ health and safety in the 
supply chain
∙	 Socioeconomic impact of 
corruption and bribery in the 
supply chain
OWN
OPERATIONS
∙	 Local pollution and hazardous 
waste from production sites 
(leakage, chemicals)
∙	 GHG emissions at production 
sites
∙	 Climate impact of transport and 
logistics
∙	 Sustainable packaging
∙	 Resource efficiency
∙	 (energy and water consumption)
∙	 Employee health and safety
∙	 Labour conditions and human 
rights of own employees
∙	 Employee development
∙	 Train global operators to facilitate 
experience in critical infrastructure 
rehabilitation 
MANAGEMENT  
& MARKETING
 
∙	 Business travel and employee 
commuting
∙	 Diversity and inclusion
∙	 Employee education and 
development
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Tax policies and payments
CUSTOMERS 
& END-USERS
∙	 Product longevity and quality
∙	 Product take-back, recycling, and 
reuse (plastics, wood, fiberglass)
∙	 End-of-life management
∙	 Environmental impact during use-
phase (styrene leakage)
∙	 Climate change capacity building 
(prevent flooding, reduce water 
contaminations)
∙	 Product safety
∙	 Contract conditions (B2B 
customers)
∙	 Trenchless: non-disruptive to the 
communities we serve
External factors impacting IMPREG based on its sector, jurisdictions, and operations
	
+ Demand for climate change mitigation solutions, e.g., products and 
services with lower CO2 emissions than alternatives
	
+ Demand for climate change adaptation solutions, e.g., solutions that 
mitigate flooding, ensure safe water, and reduce cross contamination 
of water/wastewater
	- Scrutiny of environmental and health effects of chemical toxins
	- High anti-corruption and bribery risks in key markets (e.g., China)
	- Human and labour rights concerns in high-risk locations (e.g., China)
Initial EU taxonomy assessment
Key activities
∙	 E37.00 – Sewerage
 
Potential contribution to environmental objective
∙	 Climate change mitigation
∙	 Climate change adaptation

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
80
81
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Responsible 
Investment 
Practices
	• 1a. UN PRI 
Principles 
	• 1b. TCFD 
reporting
	• 1c. Annual review 
of compliance 
processes
	• 1a. UN PRI Principles, with all 
Principles implemented 
	• 1b. Publish the annual TCFD 
report (containing Governance, 
Strategy, Risk Management, 
and Metrics and Targets)
	• 1c. Continue with the annual 
external compliance review
	• 1a. Identified UN PRI principles as 
a focus area
	• 1b. Identified TCFD reporting as 
relevant KPI
	• 1c. Completed first external 
compliance review
	• 1a. Implement principles 2 and 5 
	• 1b. Begin initial structure for TCFD 
reporting
	• 1c. Complete the second external 
compliance review of processes and 
implement proposed actions
2. Climate 
and nature-
friendly 
housing
	• 2a. GHG 
emissions 
	• 2b. Share of 
properties 
in operation 
powered by green 
energy 
	• 2a. Strive to Net Zero
	• 2b. Maintain 95% of properties 
in operation powered by green 
energy
	• 2a. Started reporting GHG 
emissions in the online portal, 
performed scope 3 screening to 
identify material categories
	• 2b. 95% of properties in operation 
are powered by green energy
	• 2a. Report full scope 1+2, and 
prepare a structure for reporting 
scope 3
	• 2b. Green energy from renewable 
sources in 95% of our properties in 
operation
3. Quality 
housing that 
promotes 
health and 
quality of life
	• 3a. Share of 
properties with 
certification 
	• 3b. Share of 
properties with 
community-pro-
moting areas 
	• 3a. Over 70% of all properties 
have achieved the Nordic 
Ecolabel (Svanemærket) or 
other recognised certifications
	• 3b. More than 60% of all 
properties in operation have a 
common room or area
	• 3a. 45% of properties purchased 
in 2022 have achieved the Nordic 
Ecolabel (Svanemærket) or other 
recognised certifications 
	• 3b. More than 28% of all properties 
in operation have common rooms 
or areas
	• 3a. More than 40% of all properties 
to achieve the Nordic Ecolabel 
(Svanemærket) or other recognised 
certifications
	• 3b. More than 35% of all properties 
in operation have common rooms 
or areas
4. Happy 
and satisfied 
employees
	• 4a. Employee 
satisfaction
	• 4b. Social 
employee 
arrangements
	• 4a. eNPS score of >= 60 and 
puls score of > 75 
	• 4b. Organise five social events 
for employees annually
	• 4a. Average eNPS score of 36 and 
average pulse score of 76 (started 
tracking from August 2022) 
	• 4b. Organised two larger employee 
social events (summer party and 
Kick-off trip)
	• 4a. eNPS score of > 50 and puls 
score of > 65 for the year
	• 4b. Organise three social events for 
employees
KONCENTON'S ESG STRATEGY 2023 
Koncenton has selected the following SDGs to which it has an opportunity to contribute:
Strengthen social communities with buildings that make it easy 
and natural for residents to meet. Senior housing concept 
units older people to combat loneliness (3.4)
Increase resource efficiency and make production processes 
more efficient through adopting cleaner and more environmen-
tally friendly industrial processes (9.4)
Efficient use of natural resources (12.2) and encourage 
companies in a less-sustainable industry to start publishing 
sustainability reports (12.6)
FSN Portfolio Company since 2022
koncenton.com
Koncenton is a leading investment provider of residential real estate 
projects, focusing on providing high-net-worth individuals with access to 
Danish residential real estate investment opportunities. Koncenton offers 
passive investments into future-proof residential properties carefully 
selected and developed to accommodate the trend-specific need for new 
housing. The properties are primarily located in the largest Danish cities 
with high population growth. For three consecutive years, Koncenton has 
held the position as the largest Danish real estate investor measured by 
transaction volume.
Koncenton’s in-house rental department, Go’ Bolig, handles marketing 
and rental of all properties under Koncenton administration and delivers 
industry-leading vacancy rates adding to the unique value proposition.
The company is headquartered in Aarhus, Denmark, and employs 110 
people in its two offices in Aarhus and Copenhagen.
Koncenton's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
SUPPLIERS 
∙	 GHG emissions from extraction 
and transportation
∙	 Nature impacts (biodiversity, 
pollution) from the extraction of 
raw materials 
∙	 Water use in the production of 
materials 
∙	 Human and labour rights 
in resource extraction and 
construction 
∙	 Anti-corruption and bribery in the 
supply chain
CONSTRUCTION 
∙	 Building design and life cycle 
management 
∙	 GHG emissions from machinery 
and transportation 
∙	 Land use and ecological impacts 
∙	 Waste from construction 
activities 
∙	 Labour health and safety 
∙	 Work-life balance 
∙	 Diversity and inclusion 
∙	 Local community impacts of 
construction and choice of areas
∙	 Climate risk assessments
∙	 Business ethics
∙	 Product quality and safety
PORTFOLIO
MANAGEMENT 
∙	 Office waste 
∙	 Energy use in own offices
∙	 GHG emissions from employees' 
travel activities
∙	 Waste handling
∙	 Employee education and 
development
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Investment policy and strategy
∙	 Compliance processes
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Data security and privacy
CUSTOMERS 
& END-USERS
∙	 Energy consumption in the use 
phase of buildings 
∙	 Water consumption in the use phase
∙	 Inclusive and affordable housing
∙	 Health and safety of tenants
∙	 Critical incident risk management
∙	 Fair access and affordability
External factors impacting Koncenton based on its sector, jurisdictions, 
and operations
	
+ Urbanisation leading to increasing demand for accessible, affordable, 
safe, and energy-efficient housing in cities 
	
+ Demand for climate resilient properties designed to minimise the 
environmental impact of full life-cycle of a building 
	
+ Investor sentiment toward and demand for climate-friendly 
investments
	- Extreme weather events increase the need and cost of maintenance, 
repairs, and preparations 
	- Scrutiny of the environmental and social impact of the construction 
value chain, leading to increased regulations and requirements 
Initial EU taxonomy assessment
Key activities
∙	 L68 – Real estate activities
∙	 F41 – Development of building projects 
Potential contribution to environmental objective
∙	 Climate change adaptation
∙	 Climate change mitigation (enabling)
Increase the global percentage of renewable energy at an 
affordable price (7.2)  
Ensure access to adequate, safe, and affordable housing and 
basic services (11.1)

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
82
83
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Reduce our 
environ-
mental 
footprint
	• 1a. Reduce GHG 
emissions
	• 1b. CO2 
compensation
	• 1c. Use of clean 
energy
	• 1d. Reduce 
climate impact 
from logistics and 
transportation
	• 1e. Reduce waste 
production YoY
	• 1a. Become Net Zero 
by 2040 
	• 1b. Offset all 
remaining emissions
	• 1c. 100% clean energy 
and use of electric 
company cars
	• 1d. Majority of 
suppliers to follow 
Net Zero initiative 
2040
	• 1e. Reduce waste 
production by 50%
	• 1a. Committed to SBTi
	• 1b. Offset 3300 tons of CO2 emissions with 
“Planted” and planted 3300 trees.
	- Hosted MEGABAD Wald planting event in 
December
	• 1c. Carpool changed from 22% hybrid/
electric in 2019 to 43% in 2022
	• 1d. 3/4 of outbound logistics partners deliver 
certified green shipping to customers
	• 1e. Started with the digitalisation of Logistics, 
Accounting, and HR departments to reduce 
paper waste & reducing wood pallet waste by 
repairing & recycling them
	• 1a. Set SBTi targets & develop 
emissions reduction plan
	• 1b. Increase MEGABAD forest 
through Planted: plant 3600 trees to 
offset 3600 tons CO²
	• 1c. Prepare car fuel compensation 
concept
	• 1d. Only work with logistic partners 
that can provide 100% green 
deliveries
	• 1e. Reduce additional 10% of paper 
& wood waste in proportion to 
revenue
2. 
Sustainable 
products and 
packaging
	• 2a. Create a 
sustainable 
product line 
(within our own 
brands)
	• 2b. Enable 
customers to save 
energy & money 
by introducing an 
“energy efficient” 
filter on the 
website
	• 2c. Sustainable 
packaging
	• 2a. Introduce 
sustainable products 
(Life Cycle Analysis 
studies as evidence) 
	• 2b. Prominent 
presence of 
sustainable (& energy 
efficient) products/ 
product lines on the 
MEGABAD website
	• 2c. 100% FSC 
certified/recycled 
packaging 
	• 2a. Development of sustainable product 
suites; focus on circularity and environmental 
sustainability (water & energy saving)
	• 2b. Started developing filters for “energy-effi-
ciency” and “sustainable products” 
	- Definition and selection of sustainable 
products
	• 2c. Cardboard packaging is FSC certified. 
Only usage of already used life-cycle plastic 
packaging, no additionally bought plastic
	• 2a. Introduction of first green 
product suites
	• 2b. Go live with filter in 2nd half 
of 2023
	• 2c. 100% Plastic Free and 100% FSC 
certified/ recycled packaging
3. Employee  
satisfaction
	• 3a. Increase eNPS
	• 3a. Regarded 1st 
choice as an employer 
in the region
	• 3a. Implemented a survey tool 
(Winningtemp) for employee satisfaction and 
eNPS. Developed and implemented a social 
intranet for better internal communication
	• 3a. eNPS of 70 and a 8/10 score in 
temperature 
	- Regular feedback loops in team 
meetings within the departments & 
quarterly publication of evaluations 
on social intranet
4. Ethical 
supply chain
	• 4a. Own Brands:
	- Proven supply 
chain trans-
parency including 
onsite supplier 
verification
	• 4b. External 
Brands:
	- Extension of the 
Supplier CoC to 
ALL departments
	• 4a. Own Brands:
	- 100% supply chain 
transparency
	• 4b. External Brands:
	- 100% of external 
brands sign SCoC
	• 4a. & b. Code of Conduct: 
	- 83% of suppliers in purchasing department 
signed Supplier CoC
	- 24% of ALL departments
	• 4a. Own Brands:
	- 100% of suppliers are to sign SCoC. 
Conduct onsite supplier visits with 
the first batch of suppliers. Further, 
formalise procedures for supply 
chain mgmt. 
	• 4b. External brands:
	- Top 50 suppliers to sign SCoC. 
Further, formalise procedures for 
supply chain mgmt. 
5. Ethical  
business 
conduct
	• 5a. Achieving 
100% 
commitment in 
ESG policies
	• 5a. Acting 100% ESG 
compliant
	• 5a. 
	- Launched updated policies 
	- Produced ESG video for website & social 
media 
	- Produced videos for ethics e-learning
	- Selection of a suitable e-learning Platform & 
electronic whistleblower channel
	• 5a.
	- Implementation of e-learning tool 
(1st step compliance themes)
	- 100% of employees to complete 
e-learning training in whistle-
blowing & CoC
MEGABAD'S ESG STRATEGY 2023 
MEGABAD has selected the following SDGs to which it has an opportunity to contribute:
Support full and productive employment and decent work for 
all, including equal pay for work of equal value (8.5)
Sound management of chemicals and all wastes throughout 
their life cycle (12.4) and reduce waste generation through 
prevention, reduction, recycling, and reuse  (12.5)
Improve education, awareness-raising, and human and 
institutional capacity on climate change mitigation, adaptation, 
impact reduction, and early warning (13.3)
FSN Portfolio Company since 2021
megabad.com
MEGABAD is a leading German e-commerce retailer for bathroom and 
sanitary products with a vast assortment of high-end to value brands along 
with a dedicated own brand portfolio comprising four brands.
In addition to its e-commerce store, MEGABAD operates one 
physical retail store in Cologne. The company is headquartered in 
Kerpen, Germany, where it also operates two warehouses to be close to its 
customers and to offer short delivery times.
MEGABAD sources the majority of its products from third-party OEMs 
based in the EU. Its private-label products are produced in the EU and 
Turkey, with fully outsourced production. The primary customer group is 
B2C, and goods are delivered to them through third party distributors.
MEGABAD's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 Climate impact from production 
(energy use, fuel type)
∙	 Industrial chemical handling, 
storage, and treatment
∙	 Emissions of particulate matter in 
the production
∙	 Environmental impact of 
transporting products and 
materials
∙	 Biodiversity impact from the 
extraction of raw materials and 
production
∙	 Labour and human rights
∙	 Workers’ health and safety
∙	 Material certificates and supplier 
management
∙	 Supply chain transparency
OWN
OPERATIONS
∙	 Climate impact of transport, 
logistics, and warehouse
∙	 Waste management
∙	 Sustainable packaging
∙	 Labour and human rights
∙	 Workers’ health and safety
∙	 Diversity and inclusion
∙	 Business ethics
MANAGEMENT  
& MARKETING
 
∙	 Sustainable and circular design
∙	 Working conditions and culture
∙	 Diversity and inclusion
∙	 Local community engagement and 
job creation
∙	 Anti-corruption and integrity
∙	 Anti-competitive behaviour 
reporting
∙	 Whistleblowing mechanisms
CUSTOMERS 
& END-USERS
∙	 Product longevity
∙	 Product take-back, recycling, and 
reuse
∙	 Climate impact of shipping and 
delivery
∙	 Product labelling and certification
∙	 Product quality and safety
∙	 Selling practices
∙	 Customer welfare
∙	 Contract conditions for customers
External factors impacting MEGABAD based on its sector, jurisdictions, 
and operations
	
+ Demand for low-impact products produced and transported 
in environmentally sound ways, considering water, waste, and 
associated emissions
	
+ Demand for products made in socially sustainable ways, with full 
supply chain transparency
	- Scrutiny on environmental impact of production, transportation, and 
end of life treatment of products
	- Scrutiny of human rights and labour conditions in the full supply chain
Initial EU taxonomy assessment
Key activities
∙	 G47.9.1 – Retail sale via mail order houses or via Internet
∙	 G46.7.3 - Wholesale of wood, construction materials and 
sanitary equipment
Potential contribution to environmental objective
∙	 Transition to a Circular Economy

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
84
85
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Sustainable 
offering 
	• 1a. GHG footprint 
of Nordlo services 
	• 1b. Average 
lifespan of utilised 
hardware
	• 1a. Services that support our 
customers' sustainability* 
goals
	• 1b. Circular services offered 
to all customers 
	• 1a. Included sustainability 
perspective in offering strategy
	• 1b. Circular offering of the workplace 
as a service can be offered to all 
customers
	• 1a. Evaluate and document the 
sustainability perspective, incl. GHG 
footprint, of our 5 largest services, 
define a method to measure the GHG 
footprint linked to these services 
	• 1b. Evaluate and document circular 
management of the services with the 
largest hardware volume, define a 
method to measure the share average 
lifespan of utilised hardware
2. 
Sustainable 
organisation 
	• 2a. GHG 
emissions
	• 2b. eNPS
	• 2c. % of female 
and non-binary 
leaders and 
operational staff
	• 2d. % of 
employees 
participating in 
data security and 
privacy training 
	• 2a. Net Zero 
	• 2b. Attractive employer with 
industry-leading employee 
satisfaction 
	• 2c. Inclusive employer with 
diversity and representation 
above the industry average
	• 2d. Reliable partner with 
secure IT solutions
	• 2a. Expanded scope 3 measuring 
with most relevant areas according 
to screening
	- Offset of measured emissions: 100% 
	- Renewable energy in data centres: 
100%
	- Renewable energy included as a 
prerequisite in data centre strategy
	• 2b. eNPS of 29
	• 2c. Female and non-binary staff: 
	- Leaders: 23% 
	- Operational staff: 8%
	- Share of internships and similar: 33%
	• 2d. All employees conducted GDPR 
update training.
	- Monthly interactive micro training 
on IT security offered to all 
employees
	• 2a. Set internal emission reduction 
plan
	- Evaluate setting targets in line with 
SBTi 
	- Continue to offset 100% of measured 
emissions 
	• 2b. Increase eNPS to 31 
	• 2c. Increase the share of female and 
non-binary leaders and operational 
staff. Continue Nordlo More initiative 
on inclusion and diversity internally. 
Implement equal sponsoring. One 
female or non-binary final candidate 
for all leadership roles
	• 2d. Monthly interactive micro 
training on IT security and GDPR for 
all employees
3.  
Sustainable 
supply chain 
	• 3a. % of purchase 
volume from 
suppliers for 
which we have 
conducted a risk 
analysis and/or 
due diligence  
	• 3a. Effective supply chain 
mgmt.
	• 3a. Updated Supplier CoC adopted. 
Electronic whistleblower channel 
procured
	• 3a. Implement due diligence and 
external communication according to 
new regulations
* Including social, economic and environmental sustainability 
NORDLO'S ESG STRATEGY 2023 
Nordlo has selected the following SDGs to which it has an opportunity to contribute:
Ensure women’s full and effective participation and equal 
opportunities for leadership (5.5)
Support the sustainable management and efficient use of 
natural resources (12.2), and reduce waste generation 
through prevention, reduction, recycling, and reuse (12.5)
Improve resource efficiency in consumption and production 
(8.4), and support full and productive employment and decent 
work for all, including equal pay for work of equal value (8.5)
Opportunity to indirectly reduce the environmental impact of 
cities (11.6) and increase their resource efficiency (11.B)
Opportunity to indirectly contribute to upgrading the 
technological capabilities of customers (9.5) 
FSN Portfolio Company since 2018
nordlo.com
Nordlo is a Nordic IT and digitalisation partner helping customers improve 
their IT environment by offering scalable IT solutions addressing the 
needs of both businesses and employees. The company offers a broad range 
of services, including managed IT, IT infrastructure, cloud services, IT 
security services, hardware and software management, as well as digital 
transformation. Services are provided through Nordlo’s data centres and 
public cloud partners. 
Nordlo is headquartered in Stockholm, Sweden, and employs ~850 
people across 46 offices in both Sweden and Norway. The key customer 
focus is companies with limited to no in-house IT departments across a 
wide range of different industries. The main customer segments are small 
to medium-sized enterprises, public institutions, and NGOs.
Nordlo's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 GHG emissions from hardware 
production
∙	 Local emissions from mineral 
extraction (hardware)
∙	 E-waste and hazardous waste
∙	 Impact on biodiversity in the 
hardware supply chain and at data 
centre sites
∙	 GHG emissions and energy 
consumption from leased data 
centre (DC) services
∙	 Water and cooling in data centres
∙	 Labour and human rights in 
hardware production
∙	 Workers’ health and safety
∙	 Socioeconomic impacts of conflict 
minerals
∙	 Corruption and bribery
OWN
OPERATIONS
∙	 E-waste and end-of-life 
management of IT equipment and 
data centre
∙	 Employee commuting and business 
travel
∙	 GHG emissions and energy 
consumption from own data 
centre services
∙	 Water and cooling used in data 
centres
∙	 Impact on biodiversity and sound 
pollution at data centre sites
∙	 Employee education and 
development
∙	 Diversity and inclusion
∙	 Data security and privacy
∙	 Professional integrity
MANAGEMENT  
& MARKETING
 
∙	 Office waste
∙	 Energy use in own offices
∙	 GHG emissions from business 
travel and employee commutes
∙	 Employee education and 
development
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Employee pensions
∙	 Data security and privacy
CUSTOMERS 
& END-USERS
∙	 Energy use of products and services
∙	 Impact on customers' production 
and resource efficiency
∙	 Digital literacy
∙	 Contributing to more efficient 
work management
∙	 Customer work-life balance (home 
office)
∙	 System reliability (lagging, 
downtime)
∙	 Contract conditions (B2B 
customers)
External factors impacting Nordlo based on its sector, jurisdictions, and operations
	
+ Demand for digital transformation services that enable the 
transition to a low-carbon economy, 
	
+ Demand for low impact and circular products and services 
	- Heightened cyber attack risks globally, putting pressure on data privacy 
and security measures 
	- Scrutiny of emissions from data centres and e-waste
	- Industry characterised by lack of diverse candidates for technical jobs
Initial EU taxonomy assessment
Key activities
∙	 J62.02 - Computer consultancy activities
∙	 J62.03 - Computer facilities management activities
∙	 G46.51 - Wholesale of computers, computer peripheral equipment and software
Potential contribution to  
environmental objective
∙	 Climate change mitigation
∙	 Climate change adaptation 
∙	 Transition to a Circular Economy

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
86
87
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Climate 
change 
mitigation 
	• 1a. Reduce GHG 
emissions
	• 1b. CO2 avoided 
	• 1c. Climate Risk 
(TCFD) 
	• 1a. Become Net-Zero
	• 1b. Produce solar energy to 
cover the energy use of a 
city of the size of L.A. 
	• 1c. Implement climate 
risk mitigation measures 
in the construction and 
day-to-day operation of 
Obton solar projects
	• 1a. Got familiar with CEMAsys and 
started reporting on scope 1, 2 and 3
	• 1b. The production of solar energy 
from Obton administrated solar parks 
in 2022 was 1,238 GWh. This is an 
increase from 2021 production of 28%.
	• 1c. Adopted Policy for integration of 
ESG risks to consider physical and 
transactional risks in the investment 
process
	• 1a. Report on GHG emissions to 
calculate a baseline year and prepare 
to set an SBTi target
	• 1b. Increase total CO2e avoided by 
Obton administered solar PV plants 
with +10 %
	• 1c. Further investigate climate 
mitigation strategies, including 
evaluation of adverse sustainability 
impacts in the investment and how 
to minimise the adverse impacts
2.  
Environment 
and natural 
resource 
preservation 
	• 2a. Circularity 
	• 2b. Biodiversity
	• 2a. Increase recycling and 
use of recycled material in 
PV plants
	• 2b. Transparently disclose 
and systematically address 
biodiversity impacts
	• 2a. Increased the share of repairable 
inverters
	• 2b. Fostered biodiversity by not using 
pesticides to keep the parks, letting 
vegetation grow, using minimum 
maintenance, and planting bushes and 
flowers
	• 2a. Establish a baseline for repaired 
or replaced solar modules, inverters, 
caples and mounting structures and 
targeting 90% coverage
	• 2b. Perform an Environmental 
Impact Assessment for every new 
greenfield development project in 
Denmark
3.  
Attractive 
and dynamic 
workplace 
	• 3a. eNPS
	• 3b. Diversity, 
Equity & 
inclusion
	• 3c. Health and 
safety
	• 3a. Maintain employee 
satisfaction with an eNPS 
at 50
	• 3b. A diverse workforce 
in an inclusive work 
environment where 
everyone is treated fairly 
and feel they belong
	• 3c. Best in class HSE 
performance
	• 3a. Populum was implemented as a tool 
to measure employee satisfaction. The 
eNPS was 50
	• 3b. Signed the Gender Diversity Pledge 
to work towards an overall gender 
distribution of 40/60 female/male in 
management and BoD.  
Currently gender distribution:
	- In the whole organisation: 62.8% men, 
37.2% female
	- Top management: 75% men, 25% 
female
	- BoD: 16.7% female, 83.3% male
	• 3c. Appointed HSE managers/advisors 
for both solar plants and offices
	• 3a. Perform a workplace assessment 
at HQ due to new facilities and 
maintain an eNPS score at 50
	• 3b. Work towards a gender 
distribution of 40/60 in the whole 
organisation
	• 3c. Offer all Obton employees to 
participate in a first aid course
4.  
Ethical and 
transparent 
business 
conduct
	• 4a. Ethical supply 
chain
	• 4b. ESG 
awareness 
training
	• 4c. Active 
industry collabo-
ration to promote 
ESG 
	• 4d. Annual ESG 
report
	• 4e. Annual review 
of compliance 
processes
	• 4a. Transparently disclose 
and manage supply chain 
risks
	• 4b. Maintain outstanding 
business ethics among 
all employees and mgmt.: 
continuously work towards 
an open and transparent 
culture
	• 4c. Active member of 
industry ESG collaboration 
	• 4d. Publish annual ESG 
reporting
	• 4e. Continue with external, 
annual compliance review
	• 4a. Adopted Policy for ESG due 
diligence and CoC for Partner and 
Suppliers to increase transparency in 
the value chain
	• 4b. Formalisation of guidance to 
marketing to prevent using words or 
sentences that could be misinterpreted 
and deemed as greenwashing
	• 4c. Became member of SolarPower 
Europe, Green Power Denmark and 
Svensk Solenergi
	• 4d. Published second ESG report
	• 4e. Completed first external review of 
compliance processes
	• 4a. Have 70% of direct solar module, 
inverter and battery suppliers 
sign Obton’s CoC for Partner and 
Suppliers or equivalent standards
	• 4b. Perform two training activities 
within Environment to increase ESG 
awareness
	• 4c. Actively engage in Green Power 
Denmark, SolarPower Europe and 
Svensk Solenergi that Obton is a 
member of
	• 4d. Publish ESG reporting and data 
for 2022 in the annual report
	• 4e. Complete second external 
compliance review of processes and 
implement proposed actions
5.  
Responsible 
investing
	• 5a. ESG processes 
in the investment 
phase
	• 5a. Continuously improve 
how ESG factors are 
integrated throughout the 
investment phase
	• 5a. Adopted policy for ESG DD and 
integration of ESG risks, that will 
improve implementation of ESG in the 
investment process
	• 5a. Strengthen ESG procedures in 
the investment process through full 
implementation of ESG DD
OBTON'S ESG STRATEGY 2023 
Obton has selected the following SDGs to which it has an opportunity to contribute:
Facilitate universal access to 
modern energy (7.1) and increase 
the global percentage of renewable 
energy (7.2)
Reduce the degradation of natural 
habitats and loss of biodiversity 
(15.5)
End forced labour, modern slavery, 
and child labour (8.7) and be a 
workplace with equal pay for equal 
work (8.5)
Reduce GHG emissions (13.1) 
and improve education, aware-
ness-raising, and climate change 
mitigation and adaptation (13.3)
Reduce waste generation through 
prevention, reduction, recycling, 
and reuse (12.5)
FSN Portfolio Company since 2021
obton.com
Obton is a specialised alternative investment provider developing, 
structuring, and managing solar photovoltaic (PV) projects and recently 
also engaged in battery storage projects. Headquartered in Denmark, 
Obton has offices around the world. Obton is one of the largest operators 
of commercial solar PV systems in Europe and we expect to become a 
significant operator of battery storage as well. Obton has more than 1,400 
solar PV plants with a total capacity of 1,728 MWp. 
Obton’s projects are predominantly located in Europe and increas-
ingly also outside Europe in countries like Japan and Canada. The 
majority of solar panels and other key components are sourced from the 
leading suppliers in China. Batteries are likewise sourced from Asia. The 
investors in the Obton-administered funds are Danish High-Net-Worth 
Individuals and the produced energy is sold, among others, through 
power purchase agreements.
Obton's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 GHG emissions from the 
production of components
∙	 Local environmental impacts (e.g., 
biodiversity, pollution) from pro- 
duction of raw materials
∙	 GHG emissions from transport of 
solar panels and battery modules 
(alternative just ‘components’)
∙	 Water use from manufacturing 
solar cells
∙	 Human rights risks related to 
conflict minerals used in solar PV 
components and battery modules
∙	 Human and labour rights in the 
supply chain
∙	 Workers’ health and safety in raw 
material extraction and production
∙	 Anti-corruption and bribery in the 
supply chain
OWN
OPERATIONS
∙	 Biodiversity impacts from 
changes in land use due to solar 
and battery storage development
∙	 GHG emissions during the 
construction and operation of solar 
and battery storage plants 
∙	 Water use for cleaning/ 
maintenance of solar panels
∙	 Choice of location - other 
utilisation value of solar and 
battery storage plant (e.g., 
agricultural land, rich biodiversity, 
or habituated land)
∙	 Health and safety risks during 
construction, operation, and 
maintenance
∙	 Local job creation
∙	 Professional integrity and honest 
advice
MANAGEMENT  
& MARKETING
 
∙	 Office waste
∙	 Energy use in own offices
∙	 GHG emissions from employee 
travel
∙	 Product design and life cycle 
management
∙	 Employee engagement, education, 
and development
∙	 Diversity and inclusion
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Data security and privacy
∙	 Systemic risk management
CUSTOMERS 
& END-USERS
∙	 Environmental impact of disposal 
and reuse of solar systems and 
battery modules at end of life
∙	 Biodiversity and green initiatives 
during operation, and restoration 
after project decommissioning
∙	 Positive environmental impact 
from the production of renewable 
energy and energy storage
∙	 Access to affordable sustainable 
energy 
∙	 Solar plant potential for recreational 
areas
∙	 Opportunity to co-own solar farms 
for local residents
∙	 System reliability (lagging, down- 
time)
External factors impacting Obton based on its sector, jurisdictions, and operations
	
+  Solar PV and energy storage are recognised as a critical technology 
to meet global climate targets and energy security in Europe 
	
+  Demand for solar panels produced in socially and environmentally 
sustainable ways
	- Scrutiny on the environmental impact of raw material sourcing and end-
of-life management of solar panels and battery modules
	- Immature market for reuse solutions
	- Human and labour rights concerns associated with the supply chain in 
higher-risk locations (e.g., China)
Initial EU taxonomy assessment
Key activities
∙	 D35.11 - Production of electricity
∙	 F42.22 - Construction of utility projects for electricity and 
telecommunications
Potential contribution to environmental objective
∙	 Climate change mitigation

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
88
89
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Reduce 
environmental 
footprint
	• 1a. SBTi 
	• 1a. GHG Net Zero
	• 1a. Baseline measured and 
reported in CEMAsys
	• 1a. Reduce GHG emissions: 
	- Reduce air travel by 10%
	- Increase the share of power contracts 
using green electricity
	- Reduce the use of fossil-driven cars by 
20%
2. The best 
workplace in 
the industry 
	• 2a. eNPS
	• 2b. Gender diversity 
	• 2a. eNPS >= 50
	• 2b. Gender balance in the 
range 45-55
	• 2a.  eNPS of 60
	• 2b. 34.5% of new trainees 
were female
	• 2a.  eNPS >= 50 
	• 2b. At least 1/3 of new hires should be 
female
3. Preferred 
partner for 
secure and 
sustainable 
solutions 
	• 3a. Number of cases 
lost data
	• 3b. ISO 27001 
certification 
	• 3c. Employer 
ranking in 
Universum’s annual 
survey
	• 3a. 0 cases of lost customer 
data
	• 3b. Be ISO27001 certified 
	• 3c. Our Academy for 
competence development 
is seen as leading in the 
industry
	• 3a. 0 cases of lost data
	• 3b. ISO27001 certified
	• 3c. Ranked #97 in employer 
attractiveness rating
	• 3a. 0 cases of lost data
	• 3b. ISO27001 certified
	• 3c. Increase employer ranking by at least 
6 positions
OMEGAPOINT'S ESG STRATEGY 2023 
Omegapoint has selected the following SDGs to which it has an opportunity to contribute:
FSN Portfolio Company since 2021
omegapoint.se
Omegapoint is a thought leader in cybersecure digitalisation. The company 
builds, operates, and defends solutions that need to work under any 
circumstances. Omegapoint serves a wide range of industries, including 
healthcare, retail, banking, manufacturing, utilities, and government. 
A majority of the company’s revenue comes from long-term customer 
relationships.  
In 2022, Omegapoint doubled in size and now has 850 employees 
spread over offices in Stockholm, Gothenburg, Malmö, Umeå, Uppsala, 
Örebro, Enköping, Copenhagen, and Oslo. The company’s culture is based 
on constant competence development, manifested in the internal Academy 
program. The company’s vision is a society where real cybersecurity is a 
natural part of all technology.
Omegapoint's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 GHG emissions and energy 
consumption from the production 
of hardware and suppliers’ data 
centres
∙	 Environmental footprint of 
hardware
∙	 Local emissions from mineral 
extraction (hardware)
∙	 Impact on biodiversity at data 
centre sites
∙	 Water and cooling used in data 
centres
∙	 Labour and human rights in 
hardware production
∙	 Workers’ health and safety
∙	 Anti-corruption and bribery in the 
supply chain
∙	 Potential of malware in hardware
OWN
OPERATIONS
∙	 E-waste and end-of-life 
management of IT equipment
∙	 Employee commuting and business 
travel
∙	 GHG emissions and energy 
consumption
∙	 Employee education and 
development
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Professional integrity and honest 
advice
MANAGEMENT  
& MARKETING
 
∙	 Office waste
∙	 Energy use in own offices
∙	 Employee education and 
development
∙	 Work-life balance
∙	 Diversity and inclusion
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Data security and privacy
CUSTOMERS 
& END-USERS
∙	 Energy use of products and 
services
∙	 Impact on customer's resource 
efficiency
∙	 Digital literacy
∙	 Data protection and personal 
information
∙	 Cybersecurity
∙	 System reliability (lagging, 
downtime)
External factors impacting Omegapoint based on its sector, jurisdictions, 
and operations
	
+ Increasing demand for cyber security services
	
+ High demand for digitalisation services as the world moves more 
online 
	- Risk of cybersecurity affecting company reputation and market share
	- Industry characterised by lack of diverse candidates for technical jobs
	- Scrutiny of emissions and e-waste from industry
Initial EU taxonomy assessment
Key activities
∙	 J62.02 - Computer consultancy activities
Potential contribution to environmental objective
∙	 Climate change adaptation 
Achieve higher levels of economic productivity through 
diversification, technological upgrading, and innovation (8.2), 
support full and productive employment and decent work for 
all women and men, including for young people and persons 
with disabilities, and equal pay for work of equal value (8.5) 
and protect labour rights and promote safe and secure 
working environments for all workers (8.8) 
Create reliable, sustainable, and resilient infrastructure to 
support economic development and the well-being of all 
citizens. Support inclusive and sustainable industrialisation. 
Increase access and integration to small-scale enterprises. 
Increase scientific research and technical capabilities in 
all countries. Facilitate technical innovation, research, and 
innovation. Equal access to information and communication 
technology. (9.1-9.5 and 9c)

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
90
91
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Sustainable 
products
Partner sustainable 
products and 
customer solutions
	• 1a. Sales share of 
products made of 
bio-based materials 
and recycled plastics 
	• 1b. Sales share 
of eco-labelled 
products to 
represent 
	• 1c. Sales share of  
wood fibre-based 
products from FSC 
and PEFC certified 
sources 
	• 1a. >70% of product sales 
by 2030
	• 1b. >50% of product sales 
by 2030
	• 1c. >90% of product sales 
by 2030
	• 1a. 53%
	• 1b. 34%
	• 1c. 53%
	• 1a. 55%
	• 1b. 37%
	• 1c. 57%
2.Ethics in the 
supply chain
Strict principles for 
supplier evaluation
	• 2a. Share of 
compliant suppliers 
with CoC 
	• 2b. Supplier risk 
management 
procedure in place
	• 2a. 100% compliance of new 
and current suppliers that 
represent a purchase value 
>50 KEUR by 2024
	• 2b. 100 % of Group subsid-
iaries have a supplier risk 
management procedure in 
place by 2024
	• 2a. 44%
	• 2b. 70%
	• 2a. 80% and all new 
suppliers 
	• 2b. 80% of Group 
subsidiaries have 
supplier risk 
management procedure 
in place
3. Emissions and 
climate impact
Race towards 
carbon neutrality
	• 3a. Virgin plastic 
reduction
	• 3b. Steel raw material 
consumption
	• 3d. CO2e intensity in 
Scope 1 and 2 (CO2e/
MEUR) 
	• 3e. GHG emissions 
reporting
	• 3a. Zero by 2030
	• 3b. 70% by 2030
	• 3c. >75%
	• 3d. Annual reduction of 
emission intensity of 5%
	• 3e.  To be defined
	• 3a. 3%
	• 3b. 24% (50% excl BFG)
	• 3c. 45% 
	• 3d. 7,.9 CO2e/MEUR 
(4.9 excl. BFG)
	• 3e. Reported downstream distribution 
in Scope 3
	• 3a. 3%
	• 3b. 26% (54% excl.BFG)
	• 3c. 50%
	• 3d. 7.5 CO2e/MEUR 
(4.5 excl. BFG)
	• 3e. Expand reporting 
to all material scope 3 
categories
4. Anti-corruption 
and business ethics
High level of ethical 
norms in all business 
dealings
	• 4a. Policy 
compliance 
confirmation by key 
individuals
	• 4b. Number of 
incidents
	• 4a. 100% by identified key 
individuals
	• 4b. Zero incidents
	• 4a. 100% by identified key individuals
	• 4b. Zero incidents
	• 4a. 100% by identified 
key individuals
	• 4b. Zero incidents
5. Diversity, equality 
and inclusion
Engaged employees 
in equal and 
enriching work 
environments
	• 5a. Gender 
distribution among 
managers with 
directly reporting 
employees
	• 5b. Discrimination 
cases
	• 5a. >30% female and 
non-binary managers
	• 5b. Zero discrimination 
incidents
	• 5a. 33% female managers
	• 5b. Zero discrimination incidents
	• 5a. >30% female 
managers
	• 5b. Zero discrimination 
incidents
OPTIGROUP'S ESG STRATEGY 2023 
OptiGroup has selected the following SDGs to which it has an opportunity to contribute:
FSN Portfolio Company since 2022  
optigroup.com
OptiGroup is a leading European distribution group offering customised 
supply solutions to B2B customers. We acquire and develop companies 
specialising in providing customers with products and services that 
enhance efficiency and contribute to a more successful business. 
Through active and long-term ownership, OptiGroup contributes with 
industry expertise and synergies between the subsidiaries.
 The companies within the Group’s four business areas – Facility & 
Safety, Packaging, Medical and Paper & Business Supplies –  supports 
more than 100,000 B2B customers, primarily within cleaning & facility 
management, hotel & restaurant, health & medical care, manufacturing 
industry and the graphical sector, with reliable and sustainable supply 
solutions that free up resources and save costs. 
OptiGroup's potential ESG impacts based on its sector, jurisdictions, and operations
SOURCING 
 
∙	 Affordable products with improved 
sustainability, reusability and 
recyclability
∙	 Supplier due diligence
∙	 General human rights and labour 
conditions in Asian suppliers
∙	 Socioeconomic impact of 
corruption and bribery 
∙	 Bio-diversity and responsible use of 
natural resources
∙	 Deforestation and sustainable 
forestry practices
∙	 Ethically sourced bio-based 
products
∙	 Product safety and restricted 
chemical substances 
OWN
OPERATIONS
∙	 GHG emissions and energy use in 
own operations
∙	 CO2 emissions in outbound 
distribution from warehouse to 
customers
∙	 Business travel
∙	 Warehouse and office waste (paper 
and plastics)
PEOPLE AND BUSINESS 
CONDUCT 
∙	 Compliance to OptiGroup’s policy 
framework
∙	 Employee wellbeing, diversity and 
work-life balance
∙	 Health & safety 
CUSTOMERS 
& END-USERS
∙	 Promotion of sustainable products 
and supply solutions
∙	 Transparent and objective product 
information
∙	 Help customers make well-informed 
buying decisions
∙	 Sustainable product innovation, 
circulator design and closed-loop 
solutions
∙	 Climate impact of distribution, 
returns and other logistics solutions 
External factors impacting OptiGroup based on its sector, jurisdictions, 
and operations
	
+ Demand for low impact and circular products produced in socially 
sustainable ways
	
+ Global health problems drives need for medical, facility, and safety 
gear
	
+ Growing need to account for emissions, materials, waste, and labour 
conditions present opportunity to develop deeper, high-impact 
relationships with value chain partners
	- Scrutiny on environmental impact of raw materials, production, and 
end-of- life management of products
	- Changing regulatory requirements with regards to single-use items and 
plastics
	- Human and labour rights concerns associated with supply chain in 
higher-risk locations (e.g., China)

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
92
93
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Sustainable 
operations
	• 1a. Reduce GHG 
emissions
	• 1b. Share of green 
electricity usage 
in operations and 
facilities
	• 1c. Share of 
electric and hybrid 
vehicles in the 
company car fleet
	• 1a. Net Zero
	• 1b. 100% of operations and 
facilities supplied with 
green energy
	• 1c. 95% of the group car 
fleet being electric or hybrid  
	• 1a. Mapped and reported scope 1, 2, 
and 3 emissions. Reduced emissions 
from distribution by 285 tons 
compared to 2021
	• 1b. Switched to 100% green 
electricity in Germany; 70% in the 
group 
	• 1c. 15% electric and hybrid vehicles 
in Germany and 13% in the group 
– process slowed down due to the 
limited availability of hybrid and 
electric cars
	• 1a. Create a full baseline for GHG 
emissions and start the process of 
setting emissions targets 
	• 1b. Increase the share of green 
electricity in key markets
	• 1c. Create an action plan for 
switching car fleet to electric and 
hybrid in all countries
2. Circular 
product offering
	• 2a. Number of 
rental offerings
	• 2b. Number of 
repair services 
	• 2a. On average 3 rental 
stations per bigger German 
city (top 20 per capita)
	• 2b. Offer repair services in 
all Rameder cities
	• 2a. Opening of 1 test station delayed
	• 2b. Offer repair services in all 
Rameder cities
	• 2a. 1 test station for rental 
business running
	• 2b. Further promote repair 
services in all German cities 
where Rameder is present 
3. Be an attrac-
tive employer
	• 3a. eNPS
	• 3b. Diversity & 
inclusion across all 
levels
	• 3c. Sick leave
	• 3a. eNPS of 30
	• 3b. 50% female white-collar 
employees (i.e., not counting 
service point and warehouse 
employees)
	• 3c. Sick leave of 2.0%
	• 3a. 
	- Started project plan for renewal and 
modernisation of Rameder HQ
	- Transformation Project “new 
leadership / one Rameder” started 
eNPS:
2022: No survey was performed
2021: 11
2020: 29 
2019: 11
	• 3b. Partnership with Diakonie 
Stiftung Christopherus Hof for 
inclusion of people with limited 
health
	- Female white-collar employees:
2022: 46%
2021: 45%
	• 3c. Sick leave:
2022: 4.9 %
2021: 3.9 % (COVID19)
2020: 3.6 %
	• 3a. 
	- Start using the new eNPS tool 
	- Renewal and modernisation of 
the headquarter 
	- Execution of the leadership 
transformation
	• 3b. 48% female white-collar 
employees
	- Implement benefits such as 
kindergarten support, further 
HSE measures, and promote 
part-time job opportunities to 
increase the number of female 
employees 
	• 3c. Sick leave of 3.0 %
4. Safe products 
and services
	• 4a. Number of 
accidents 
	• 4b. Number of 
lifelong guarantees
	• 4a. Zero accidents are 
known to Rameder as a 
result of faulty installations
	• 4b. 100% for all self-in-
stalled tow bars 
	• 4a. Zero accidents are known
	•  to Rameder as a result of faulty 
installations
	• 4b. 100% for all self-installed tow 
bars 
	• 4a. Zero accidents are known 
to Rameder as a result of faulty 
installations
	• 4b. 100% for all self-installed 
tow bars 
5. Sustainable 
supply chain
	• 5a. Share of 
suppliers with 
signed Supplier 
Code of Conduct 
(SCoC)
	• 5b. Increase 
employees HSE 
equipment and 
ESG knowledge
	• 5a. 98 % of supplier volume 
to sign SCoC
	• 5b. Fully trained and 
equipped employees
	• 5a. % of supplier volume signing 
SCoC
2022: 85
2021: 85
2020: 82
2019: 67
	• 5b. Equipped all workers with 
special safety shoes and most office 
employees with electrical desks  
	• 5a. 26 suppliers to sign the SCoC, 
representing 90% of purchase 
volume
	• 5b. Select, install, and implement 
eLearning system for employees
RAMEDER'S ESG STRATEGY 2023 
Rameder has selected the following SDGs to which it has an opportunity to contribute:
Ensure sustainable consumption and production patterns:
12.2 By 2030, achieve the sustainable management and efficient use of natural 
resources
12.5 Substantially reduce waste generation through prevention, reduction, 
recycling, and reuse
12.6 Encourage companies to adopt sustainable practices and to integrate 
sustainability information into their reporting cycle
12.8 By 2030, ensure that people everywhere have the relevant information and 
awareness of sustainable development and lifestyles in harmony with nature 
10 %
100%
100
100%
FSN Portfolio Company since 2019
kupplung.de – rameder.eu
Rameder is the leading European e-commerce platform for automotive 
transport products and solutions enabling and encouraging its customers 
to enjoy an active lifestyle in the outdoors. The company has developed 
its position through market leadership in key European markets, a multi-
channel e-commerce product offering as well as a best-in-class service and 
solutions portfolio.
Rameder has local operations in Germany, France, Finland, Sweden, 
Switzerland, and the Czech Republic, resulting from an active buy-and-build 
strategy with nine acquisitions in recent years. Rameder targets both B2B 
as well as B2C customers and operates more than 70 installation centres, 
enabling a fully-integrated experience for the end customers. The company 
is headquartered in Germany and employs about 400 employees in Europe.
Rameder’s products are sourced directly from suppliers, all of which are 
exclusively located in Europe.
Rameder's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 Biodiversity impact of raw material 
sourcing (steel, plastic)
∙	 Energy consumption at the 
production site
∙	 Hazardous waste (ROHS)
∙	 Labour and human rights in the 
supply chain
∙	 Supply chain transparency
OWN
OPERATIONS
∙	 Product waste occurring in 
garages
∙	 Waste from packaging (paper, 
plastic)
∙	 GHG emissions from in- and 
outbound logistics
∙	 Energy consumption in warehouses 
and garages
∙	 Employee health and safety
∙	 Diversity among employees in 
garages
∙	 Employee training and 
development
∙	 Corruption and bribery 
MANAGEMENT  
& MARKETING
 
∙	 Energy consumption in sales offices
∙	 Commute and business travel
∙	 Office waste
∙	 Philanthropic activities focusing on 
environmental impact
∙	 Employee training and 
development
∙	 Diversity
∙	 Employee health and safety
∙	 Philanthropic activities focusing on 
social impact
∙	 Corruption and bribery
∙	 Data privacy and security of 
employee and company data
CUSTOMERS 
& END-USERS
∙	 End-of-life product management 
(e.g., waste vs. recycling)
∙	 Product longevity and maintenance
∙	 Higher emissions from vehicles when 
pulling trailers etc.
∙	 Product quality and safety
∙	 Making outdoor activities 
accessible, improving quality of life
∙	 Data privacy and security of 
customer data
External factors impacting Rameder based on its sector, jurisdictions, 
and operations
	
+ Demand for products supporting the circular economy through 
lifelong repair and return services
	
+ Active lifestyles and outdoor activities associated with improved 
overall health 
	- Scrutiny on human and labour rights among 2nd tier suppliers, putting 
pressure on supply chain management
	- Scrutiny of the environmental impact of raw materials, transportation, 
and end-of-life of products 
Initial EU taxonomy assessment
Key activities
∙	 45.32 - Retail sale of motor vehicle parts and accessories, 
except motorcycles
Potential contribution to environmental objective
∙	 Transition to a Circular Economy

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
94
95
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Increase
circularity and
reduce climate
impact
	• 1a. Reduce GHG 
emissions
	• 1b. Circular 
operations
	• 1c. ISO 14001 
certification
	• 1a. Net Zero
	• 1b. Zero waste to 
landfill; reuse where 
possible, recycling as 
a last resort
	• 1c. 100% of 
production units 
ISO 14001 certified
	• 1a. Scope 1, 2, and 3 included in 2022
	• 1b. Circular initiatives in the process: 
beam recycling in the Netherlands
	• 1c. 64% of units certified adding Eurostar 
AS
	• 1a. Commit to SBTi
	• 1b. Circular initiatives in the 
process: heat recycling in hot dip 
galvanising (HDG) plant in Vik 
Ørsta
	• 1c. ISO 14001 certification of 
Saferoad Pomerania in Poland. Total 
of 10 certified (71%)
2. Sustainable 
products
	• 2a. Environmental 
product lines
	• 2b. EPDs
	• 2a. Environmentally 
friendly product 
family alternatives 
for all main product 
groups
	• 2b. EPDs for 100% 
of our key product 
groups by end of 
2025
	• 2a. Delays in product development 
initiative, due to capacity constraints and 
raw material shortage 
	• 2b. Uniform EPD solution for RRS as well 
as new PIM system. Current portfolio 
with EPDs 27.2%
	• 2a. Finalise new environmentally 
friendly RRS product family 
approved to local containment level 
according to the European Standard 
EN1317
	• 2b. Target 45% of the portfolio
3. Ensure 
health,
safety, and
satisfaction of
own employees
	• 3a. ESG leadership
	• 3b. Lost time 
incident rate (LTI)
	• 3c. eNPS score
	• 3d. Business Units 
with negative eNPS 
scores
	• 3a. Saferoad 
recognised as an 
ESG leader by 
stakeholders
	• 3b. Zero LTI
	• 3c. eNPS of >70
	• 3d. 0 Business Units 
with negative eNPS 
scores
	• 3a. Completed Communication on 
Progress to UNGC and published ESG 
report 
	• 3b. LTI of: 
2022: 57
2021: 48
2020: 58 
2019: 62
	• 3c. eNPS
2022: 29
2021: 23.5
2020: 24.9 
2019: 28.0
	• 3d. 0
	• 3a. Establish a new ESG function 
in Saferoad to further build 
internal capabilities. Align our ESG 
reporting with the GRI standards
	• 3b. LTI of 48
	• 3c. eNPS of 35
	• 3d. 0
4. A  
transparent
and sustainable
supply chain
	• 4a. Supply chain 
management
	• 4b. Business units 
implement supplier 
Code of Conduct
	• 4c. Digital Supplier 
Self Assessment 
	• 4d. Mitigating plans 
agreed with critical 
suppliers with low 
scores on Supplier 
Self Assessment
	• 4a. Best in class 
supply chain mgmt.
	• 4b. 100% of Business 
Units
	• 4c. 100% of critical 
suppliers
	• 4d. 100% of critical 
suppliers
	• 4a. Yearly screening of all major suppliers 
performed. Targeted additional screenings 
were performed to ensure sanctions 
compliance, re Ukraine crisis
	• 4b. 100% of phase 1 (confirmation and 
compliance)
	• 4c. 90%
	• 4d. Dialogue started with all critical 
suppliers with low scores.
	- Concluded 50% of critical suppliers with 
low scores
	• 4a. Yearly screening of all major 
suppliers. Continued focus on 
sanctions compliance, re Ukraine 
crisis
	• 4b. 100% of phase 2 (Supplier 
audits) critical suppliers 
	• 4c. 100% of critical suppliers
	• 4d. 100% of critical suppliers
5. Ensure 
ethical
business  
conduct
	• 5a. ESG training
	• 5b. Cyber awareness 
training 
	• 5c. Electronic 
whistleblower (WB)
	• 5a. Employees 
undergo annual ESG 
training
	• 5b. 100% of 
employees 
	• 5c. Electronic WB 
access for internals 
and  externals
	• 5a. ESG training completed for Saferoad 
Procurement Network
	• 5b. Hoxhunt onboarding rate of 61.4%
	• 5c. Saferoad Sweden continues on 
standard Saferoad WB solution due to 
carve out of RRS into a separate legal 
entity
	• 5a. Roll out revised ESG e-learning 
in full group 
	• 5b. 90% of employees to complete 
training by Q1 2023
	• 5c. Update of Whistleblower 
policy to align with the Norwegian 
Transparency Act
SAFEROAD'S ESG STRATEGY 2023 
Saferoad has selected the following SDGs to which it has an opportunity to contribute:
30
100
Contributes to target 3.6, road traffic accidents, by providing 
products that increase road safety
Promote safe working environments for all employees through 
HSE training and audits (8.8)
Contributes to several targets by focusing on resource 
efficiency and waste reduction 
Contributes to target 9.1, quality, reliable, sustainable, 
and resilient infrastructure, by providing high-quality road 
infrastructure components
FSN Portfolio Company since 2018
saferoad.com
Saferoad Group is a leading road safety supplier in Europe with 75 years 
of experience within the industry. Saferoad Group offers a broad range of 
innovative and high-quality products and solutions. Saferoad serves customers 
from early road design through manufacturing, installation, and ongoing 
maintenance in four core business areas: (1) Road Restraint Systems; (2) Signs 
and Work Zone Protection; (3) Light Poles and Masts; and (4) Road Services. 
Saferoad's key customer segments vary by product and geography but span 
from light manufacturers, wholesalers, installers, and construction companies 
to road authorities, governments, and municipalities. The Group employs 2500 
people and has production and sales offices across 13 countries in Europe. 
Main production sites are located in Norway, Sweden, and Poland. Input 
materials are predominantly sourced from Europe, but also from Asia.
Saferoad's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 Energy consumption in raw material 
production (steel, aluminium, 
plastic, recycled alternatives)
∙	 GHG emission from production 
(zinc, aluminium, steel)
∙	 Labour conditions and human 
rights in raw material production
∙	 Workers' health and safety
∙	 Supply chain transparency
∙	 Business ethics in procurement 
practices
OWN
OPERATIONS
∙	 GHG efficiency at production sites 
∙	 Water consumption and waste-
water management at production 
sites 
∙	 Management of hazardous  
substances and waste
∙	 Environmental legacy risk at  
production sites
∙	 Material utilisation and recycling 
∙	 Chemical use and pollution
∙	 Health and safety of own 
employees (production sites, 
maintenance, installation)
∙	 Labour and human rights 
(production sites, maintenance, 
installation)
∙	 Traceability of raw materials (e.g., 
risk of counterfeit)
MANAGEMENT  
& MARKETING
 
∙	 Product innovation: climate 
resilient products (e.g., extreme 
weather) 
∙	 Product innovation: product 
longevity and ease of maintenance
∙	 Transportation of products to 
market
∙	 Product innovation: product quality 
and safety (e.g., can sustain the 
impact of heavier vehicles) 
∙	 Diversity and anti-discrimination
∙	 Employee education and  
development
∙	 Employee benefits
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Integrity and realistic advice
CUSTOMERS 
& END-USERS
∙	 Environmental impact of products 
during use-phase
∙	 End-of-life product management 
∙	 Improved site working conditions
∙	 Road accidents and safety
∙	 Public and customer health and 
safety
∙	 Product reliability (quality and 
safety throughout product 
lifetime)
∙	 Integrity of partners and customers
External factors impacting Saferoad based on its sector, jurisdictions, 
and operations
	
+ Continued increased demand for road rehabilitation and 
infrastructure resilient against extreme weather events
	
+ Demand for products with a lower environmental footprint than its 
competitors
	- Increasing cost and climate impact of of raw material sourcing, 
transportation, and production
	- Health and safety of workers in own production and supply chain
	- Scrutiny of human rights and labour conditions in the full supply chain
Initial EU taxonomy assessment
Key activities
∙	 C25.11 Manufacture of metal structures and parts of structures
∙	 C33.11 Repair of fabricated metal products
∙	 M71.12 Engineering activities and related technical consultancy
Potential contribution to  
environmental objective
∙	 Climate change mitigation (enabling)
∙	 Climate change adaptation
∙	 Transition to a circular economy

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
96
97
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Minimise our 
environmental 
footprint 
	• 1a. Move from 
PVC into recycled 
and biodegradable 
materials
	• 1b. Reduce GHG 
emissions
	• 1a. 100 % eco friendly 
hardware 
	• 1b. Net zero by 2050
	• 1a. 0.3 ton converted to biode-
gradable materials from PVC; 
Looked into all hardware products 
to find better solutions. 
	• 1b. Kicked off reporting in online 
GHG portal
	• 1a. Convert 1 ton of PVC 
hardware into biodegradable 
materials (120 000 pcs)
	• 1b. Quantify and report GHG 
emissions (scope 1- 2), initial 
assessment of Scope 3 emissions
2. People 
empowerment 
	• 2a. Employee 
well-being survey
	• 2b. Gender balance 
in the organisation 
	• 2a. Well-being average score 
above 90%
	• 2b. 50/50 gender balance
	• 2a. Subsidiary company, Areff has 
completed the survey 
	• 2b. 16% women among Seriline 
Groups’ FTE´s
	• 2a. Roll out a well-being survey 
in the Group, with a 95% 
response rate
	• 2b. 20% women in the Seriline 
Group
3. Ensure a 
sustainable 
supply chain 
	• 3a. Number of 
suppliers signing 
the supply chain 
CoC
	• 3a. 100% of our suppliers 
	• 3a. Adopted a new Suppliers CoC
	• 3a. 80% of hardware suppliers 
(representing over 95% of sales 
volume to sign the CoC)
SERILINE'S ESG STRATEGY 2023 
Seriline has selected the following SDGs to which it has an opportunity to contribute:
Support full and productive employment and decent work for 
all, including equal pay for work of equal value. (8.5). Provide 
good employment opportunities for the youth (8.6)
Develop quality, reliable, sustainable and resilient infra-
structure to support economic development and human well 
being (9.1)
Enhance sustainable urbanisation (11.3)
Reduce resource consumption by developing circular product 
attributes and minimising waste in production process (12.5)
FSN Portfolio Company since 2022
 seriline.com
Seriline offers a one-stop-shop for physical access management solutions, 
incl. systems for physical credentials (primarily access cards and tokens), 
RFID/card readers, and identity management systems. Most customers 
have an integrated software and hardware solution.
Headquartered in Stockholm, Sweden, the company primarily operates 
in Sweden with growing sales in the Nordics and select Western European 
countries. The company supplies a wide range of customers spanning 
across society both in the private and public sectors. The company employs 
50 people, with production sites in Stockholm and Ronneby, as well as sales 
offices across Sweden. The main raw materials are electronics and PVC 
plastics sourced from Europe and Asia.
Seriline's potential ESG impacts based on its sector, jurisdictions, and operations
RAW MATERIALS
& SUPPLIERS 
∙	 Pollution and emissions generated 
by raw material extraction and 
production (petroleum, chlorine, 
chalk)
∙	 Health impact of vinyl chloride, 
phthalates, and other additives 
used and released in the PVC 
manufacturing/recycling process
∙	 Human rights and labour conditions 
across the raw materials supply 
chain
OWN
OPERATIONS
∙	 GHG emissions and energy 
consumption from own RFID card 
and credential production facilities
∙	 Sales force car emissions
∙	 Logistics emissions, especially for 
products sourced from Asia
∙	 Logistics emissions for packages 
sent to customers using the postal 
service
∙	 Employee education and 
development
∙	 Diversity and inclusion
∙	 Data security and privacy
MANAGEMENT  
& MARKETING
 
∙	 Sustainable product innovation, 
energy reduction, and circular 
design
∙	 Employee well-being and company 
culture
∙	 Diversity and inclusion
∙	 Supplier mgmt. focused on eco-
friendly practices, health & safety, 
and the protection of human rights
∙	  Anti-corruption and bribery 
∙	 Data and information security 
CUSTOMERS 
& END-USERS
∙	 Product durability and recyclability
∙	 Energy-efficient products & digital 
tools for building management 
∙	 Climate impact of buildings
∙	 Transparency of materials, labelling, 
and product safety
∙	 Customer safety and privacy
∙	 System reliability (downtime)
∙	 Contributing to compliance with 
data security regulations (e.g GDPR, 
NIS2)
External factors impacting Seriline based on its sector, jurisdictions, and operations
	
+ Technical upgrades of buildings, including safety and access 
products
	
+ Increased expectations for environmentally friendly (recyclable) 
solutions
	
+ Increased compliance regulations (e.g. GDPR and NIS2)
	- Increased security awareness with heightened cyber attack risks 
globally, putting pressure on privacy and security measures
	- Scrutiny on climate footprint of industry solutions

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
98
99
FOCUS 
AREA
KPIS
LONG TERM 
TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Minimise 
environ-
mental 
impact
	• 1a. Reduce 
GHG emissions
	• 1b. Optimise 
energy 
efficiency 
(GHG 
emissions 
relative to 
output)
	• 1c. Circular 
operations 
	• 1d. Local 
environmental 
impact from 
operations
	• 1a. Net zero
	• 1b. 5% year by year 
energy efficiency
	• 1c. Zero waste 
to landfill; reuse 
where possible
	• 1d. Minimal 
environmental 
degradation of 
excavation sites
	• 1a. Did not commit to Science Based Targets 
in 2022. Further investigation is needed to set 
objectives in scope 3
	- Emissions* in 2022: 
Scope 1: 22,703.2 tCO2e (-7.2% from 2021)
Scope 2: 2,832.2 tCO2e (-6.8% from 2021)
Scope 3: 37,753.6 tCO2e (-5.8% from 2021)
	• 1b. Introduced “reduce energy” as a strategic 
priority:
Minimise dependency on gas 
Reduce GHG emissions
	• 1c. Approx. 1,000 pallets returned in 2022.
Further strengthened incentive to return pallets
	• 1d. Restore excavation sites, with a positive impact 
on biodiversity
	• 1a. Set Science Based Targets for scope 
1-3
	• 1b. Determine which initiatives to 
pursue to reduce environmental 
impact e.g., alternative energy sources. 
Optimise energy efficiency (GHG 
emissions relative to output) by 5% 
compared to 2020.
Implement a continuous waste 
reduction culture targeting an annual 
reduction of >2%
	• 1c. Further extend recycling of pallets
	• 1d. Continue to restore excavation 
sites, with a positive impact on 
biodiversity
2.  
Sustain-
able 
products
	• 2a. EPDs for 
our products
	• 2b. Design for 
circularity
	• 2a. EPDs for 100% 
of our product 
groups by end of 
2024
	• 2b. Cradle-to-
cradle design of 
our products
	• 2a. EPD for 33% of product groups introduced
	• 2b. Prepared recycling of cut-offs from selected 
customer projects in 2023
	• 2a. EPDs for 100% of our product 
groups
	• 2b. Introduce recycling of cut-offs 
from selected customer projects
3.  
Motivated, 
safe, and 
healthy 
employees
	• 3a. eNPS
	• 3b. Lost time 
incidents (LTI)
	• 3c. Diversity
	• 3a. Year by year 
improvement of 
eNPS
	• 3b. Zero LTI
	• 3c. Balanced 
make-up between 
male and female 
representatives 
in top leadership/ 
management
	• 3a. eNPS**
2022: 6 (11 at end of the year)
2021: -3
2020: -7
2019: NA
2018: -8
	• 3b. A new EHS improvement roadmap was made 
in cooperation with an external consultant. 
Trained all Skamol employees in safety awareness.
	- Lost Time Injury*** per million worked hours:
2022: 20.0
2021: 9.0
2020: 5.2
2019: 7.9
2018: 10.0
	• 3c. 14% female managers compared to 86% male 
managers (14% female managers in 2021)
	• 3a. Increase eNPS to 14.
Increase response rate to get better 
insight combined with follow-up 
meetings with local managers
Better communication of ESG work on 
the website
	• 3b. Reduction in LTI. Roadmap for 
Health & Safety is generated with a 
focus on:
1. Management / Organisation
2. Processes / Preventive
3. Systems / Tools
4. Awareness / Personal
	• 3c. Further extend balance between 
genders
4. Ethical 
supply 
chains and 
business 
conduct, 
including 
human 
rights and 
anti- 
corruption
	• 4a. Supply 
chain 
management
	• 4b. Train 
employees
	• 4c. Electronic 
whistleblower
	• 4a. Best in class 
supply chain 
management
	• 4b. Annual training 
for all employees
	• 4c. Electronic 
whistleblower 
access for internals 
and  externals
	• 4a. All major**** suppliers have signed CoC
	• 4b. All employees are assigned to monthly 
e-learning courses about cyber security and GDPR. 
CoC e-learning available for all Skamol employees 
beginning of 2023
	• 4c. Electronic whistleblower available on Skamol’s 
official website
	• 4a. Further strengthen supply chain 
management by conducting a refresh 
risk assessment and review current 
procedures
	• 4b. Secure all relevant employees have 
completed CoC and GDPR training
*Prepared in accordance with the GHG Protocol, using the online reporting tool CEMAsys ©. Russia is excluded from 2021 and 2022
**Russia is excluded from the 2018, 2020, 2021, and 2022 eNPS
***Injury sustained by an employee that leads to loss of productive work in the form of absenteeism or delays. Russia is excluded from the 2018, 2020, 2021, and 2022 LTI
****Major suppliers are defined as having a spend > 1mDKK
SKAMOL'S ESG STRATEGY 2023 
Skamol has selected the following SDGs to which it has an opportunity to contribute:
10
0
25
Opportunity to make the production process more efficient 
and increase resource efficiency by adopting cleaner and more 
environmentally friendly industrial processes (9.11)
Restore terrestrial land (15.1)
Efficient use of natural resources (12.2) and reduce 
waste generation through prevention, reduction, 
recycling, and reuse (12.5)
FSN Portfolio Company since 2013
skamol.com
Skamol produces and markets insulation systems based on three key raw 
materials: calcium silicate, vermiculite, and moler. 
The system portfolio spans bricks and blocks, insulation boards, and 
fire protection boards which drive health-, safety- and energy-preserving 
benefits for customers and end users around the world.
The Building sector provides easy-to-install systems for both 
renovation and new build projects, while the Industry sector provides 
systems to industrial customers handling heat intensive materials 
or niche applications requiring superior insulation properties at low 
weights. Skamol’s mission is to enable smarter, healthier, and more 
sustainable living and the use of energy resources in homes and industries 
across the globe. The company is headquartered in Denmark and serves a 
global market (more than 70 countries) with its own sales force or agents 
in all regions.
Skamol's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 Climate impact of  
raw material sourcing
∙	 Water use and pollution in sourcing
∙	 Responsible use and reparation of 
land areas in raw material sourcing
∙	 Biodiversity impact from raw 
material extraction
∙	 Supplier labour conditions and 
human rights
∙	 Supplier health and safety
∙	 Supply chain transparency
OWN
OPERATIONS
∙	 GHG emissions from  
production sites
∙	 Chemicals and pollution 
in production
∙	 Resource efficiency, waste  
management and recycling
∙	 Environmental impact of  
packaging material and waste
∙	 Water consumption in the 
production process
∙	 Employee health and safety
∙	 Labour conditions and human 
rights at production sites
MANAGEMENT  
& MARKETING
 
∙	 GHG emissions from employee 
commutes and business travel
∙	 Office waste 
∙	 Employee talent and development
∙	 Diversity and equal opportunities
∙	 Anti-corruption and bribery 
∙	 Anti-competitive behaviour
CUSTOMERS 
& END-USERS
∙	 GHG emissions from shipping and 
deliveries
∙	 Enabling energy savings from 
products in use-phase
∙	 Product longevity
∙	 Product take-back and circular 
design
∙	 Customers CO2 emissions
∙	 Product quality and safety (e.g. 
fire-safe products, improved indoor 
environment)
External factors impacting Skamol based on its sector, jurisdictions, and operations
	
+ Demand for products that reduce energy consumption,  
thereby enabling cost savings and climate change mitigation
	
+ Demand for circular products and responsible end-of-life treatment 
	- Climate impact of energy usage in production
	- Scrutiny of the environmental impact of supply chain and production on 
water and biodiversity
	- Immature market for end-of-life use of products

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
100
101
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Climate 
efficient  
operations
	• 1a. Reduce 
GHG emissions
	• 1b. GHG 
efficient 
logistics
	• 1a. Net Zero
	• 1b. Optimised transport 
routes
	• 1a. The complete baseline will be done when 
figures of 2022 are complete.
	• 1b. Completed move to European central 
warehouse. Major positive impact in 
shortening the transportation routes and the 
environmental impact. 56% shorter transports 
between SNS and customer (inbound not 
included i.e.actual figures are even higher)
	• 1a. Create a full baseline for GHG 
emissions and start the process of 
setting emissions targets.
	• 1b. Negotiate climate friendly 
transport options with carriers. 
Increase partners that climate 
compensate from 1 (Germany) to 3
2. 
Sustainable 
products
	• 2a. Circular 
products
	• 2b. Sustainable 
products
	• 2a. Offer products 
designed for circularity
	• 2b. All products 
sustainably produced 
	• 2a. Plan set of when and how to start working 
with recycled cotton.
	• 2b. Launched SNS Labels Jersey line in 100% 
Organic GOTS certified cotton. 
	- First SNS Label styles produced by deadstock 
material. 2 scues launched Summer/Fall had 
zero CO2 emission from fabrics
	• 2a & 2b. Switch to 50%Organic 
GOTS certified cotton and 50% 
recycled cotton.
	• Set up structures to ensure 
sustainable choices are always made 
when possible.
	- Sourcing at least 1 product in each 
collection by deadstock material
3. Motivated 
and satisfied 
employees 
	• 3a. eNPS
	• 3b. ESG 
leadership
	• 3c. Community 
initiatives
	• 3a. eNPS of 50
	• 3b. ESG systematically 
implemented in all SNS 
decisions
	• 3c. Develop SNS 
Care to work in close 
partnerships with brand 
partners and continue 
giving back to the 
culture we are a part of
	• 3a. eNPS score:
November 2022: 10
June 2022: -4
2021: -15
	- Positive trends connected to improved  
organisational structures, working processes, 
clear goals and expectations. Increased staff 
turnover and a stronger team via external 
talent, and internal promotions.
	• 3b. Relaunch of ESG and D,E&I Task Force. 
Instead of executive management driven à 
employee driven
	• 3c. Separate “SNS Cares” Task Force to be 
launched
	• 3a. Increase employee satisfaction 
rate by 25 points by the end of 2023. 
Main focus: leadership devel-
opment, implementing core values, 
and cross functional collaboration.
	• 3b. Set roadmap for ESG devel-
opment. Combine local activities 
with company wide activities.
	• 3c. Implement regular care projects 
driven by local teams. More than 10 
local cares activities during 2023
4. Promote 
high 
standards 
of business 
ethics
	• 4a. ESG 
awareness 
amongst 
employees
	• 4b. 
Whistleblower
	• 4a. Employees trained 
annually in ESG topics 
	• 4b. Whistleblower 
scheme known to all
	• 4a. ESG Task force relaunched. Wider team 
engaged to set SNS ESG agenda and to push 
various projects. 
	• 4b. Whistleblower policy is a part of the 
CoC that all employees sign as part of the 
onboarding process.
	• Digital channel for whistle blowing function 
launched
	• 4a. ESG Task force relaunched. 
Wider team engaged to set SNS ESG 
agenda and to push ESG projects.
	• 4b. No actions planned for 2023
5. Sustain-
able and 
ethical 
supply chain
	• 5a. Supply 
chain 
management 
	• 5b. Supply 
chain code of 
conduct (sCoC)
	• 5a. Best in class supply 
chain management
	• 5b. 100% of suppliers 
sign CoC
	• 5a. Reshoring SNS Label production to 
Europe.
	- 2022: 85% in Europe, 15% China.
	• 5b. Brand partners that have signed the 
supplier CoC
2022: 52/88
2021: 38/58
2020: 23/43
	• 5a. SNS Label production fully 
relocated to Europe.
	• 5b. 100% of suppliers to sign 
supplier CoC. Move from printing 
physical documents to signing 
digitally
SNS' ESG STRATEGY 2023 
SNS has selected the following SDGs to which it has an opportunity to contribute:
8.8 Protect labour rights and promote safe and secure 
working environments for all workers, including migrant 
workers, in particular women migrants, and those in precarious 
employment
12.5 By 2030, substantially reduce waste generation through 
prevention, reduction, recycling and reuse
12.8 By 2030, ensure that people everywhere have the 
relevant information and awareness for sustainable devel-
opment and lifestyles in harmony with nature
FSN Portfolio Company since 2018
sneakersnstuff.com
SNS Group (Sneakersnstuff ) is a global online and physical retailer of 
sneakers and apparel, as well as a creative contributor to street culture. The 
primary product segments are limited edition/rare sneakers sold through 
raffles, normal premium sneakers, apparel & accessories.
SNS is headquartered in Sweden and operates seven physical stores 
in Europe, the United States and Japan. Further, its online shop ships to 
customers across 63 countries. To reach the customers, SNS has three 
warehouses in Grobbendonk (Belgium), New York, and Tokyo.
Products are primarily branded goods from brands like Nike and 
Adidas, but SNS also sells its own-branded products. All products are 
sourced from a select number of third-party suppliers. SNS’ customer base 
is primarily younger consumers with a great interest in the sneaker and 
streetwear culture.
SNS' potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 Water depletion and pollution in 
cotton and rubber supply
∙	 Local pollution from chemicals in 
textile production (e.g. dyeing)
∙	 GHG emissions and energy use in 
cotton and rubber production
∙	 GHG emissions from  
transportation
∙	 Labour and human rights in 
cotton and rubber factories
∙	 Workers’ health and safety
∙	 Socioeconomic impact of 
corruption and bribery in the 
supply chain
PRODUCTION
∙	 Local pollution from chemical use  
in footwear production
∙	 Energy use and GHG emissions 
from footwear factories
∙	 Cotton and rubber waste at  
production sites
∙	 Packaging waste (paper, plastic)
∙	 Labour conditions and human 
rights in fabric factories
∙	 Health and safety in fabric 
factories
∙	 Diversity and inclusion
MANAGEMENT  
& MARKETING
 
∙	 GHG emissions from outbound 
logistics
∙	 Energy consumption in sales offices
∙	 Employee commuting and  
business travel
∙	 Office waste 
∙	 Cotton and rubber waste  
from outdated collections
∙	 Diversity and inclusion
∙	 Social impacts of marketing 
activities (body image, 
representation)
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
∙	 Data security and privacy
CUSTOMERS 
& END-USERS
∙	 Textile waste from used / torn / 
discarded footwear
∙	 Packaging waste (paper, plastic)
∙	 Product health impacts in use  
(e.g. toxins)
∙	 Contract conditions for customers
External factors impacting SNS based on its sector, jurisdictions, and operations
	
+ Demand for low impact and circular products and services (e.g., 
longevity, recycling, re-use)
	
+ Demand for products and services that promote diversity and 
inclusion
	- Scrutiny of environmental footprint of apparel industry
	- Scrutiny of human rights and labour conditions in the supply chain
	- Immature market for end-of-life use of used and torn shoes
Initial EU taxonomy assessment
Key activities
∙	 G47.71 - Retail sale of clothing in specialised stores
∙	 G47.72 - Retail sale of footwear and leather goods in 
specialised stores
Potential contribution to environmental objective
∙	 Transition to a Circular Economy
  
100
0

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
102
103
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Climate
	• 1a. Reduce 
emissions 
	• 1a. Net Zero
	• 1a. Sat scope 2 emissions targets: to actively 
procure at least 80% renewable electricity 
by 2025 and 100% by 2030
	• 1a. Assess the possibility of 
switching to green energy when 
producing software 
	- Assess the possibility of using 
public transportation in each region 
of our office locations
	- Organise team/activities to support 
local reduction initiatives 
2.  
Trans-
porting end 
customers 
in safe and 
climate 
efficient 
ways
	• 2a. Products for 
safety relevant 
applications
	• 2b. Climate change 
mitigation
	• 2a. Continuously push 
the bar for safety 
products
	• 2b. Quantify life-cycle 
GHG emission reduc-
tions from TASKING’s 
activities
	• 2a. Expanded product offering by launching 
the Smart-Code tool
	• 2b. Organised a global administration 
team to check regionally the impact of 
TASKING’s activities
	• 2a. Maintain a high level of safety 
and quality of our products; 
complete TISAX Audit for 
TASKING B.V. (Netherlands office) 
	• 2b. Make a GHG emission reduction 
plan for TASKING’s activities and 
enrol the first measures in 2023
3. Diversity 
& Inclusion
	• 3a. Increase the 
share of female 
employees across 
levels (with a 
stronger focus on 
technical roles) 
	• 3b. Increase the 
number of female 
employees in each 
country
	• 3c. Increase 
the number of 
employees with 
different cultural 
backgrounds in 
monocultural teams
	• 3a. 30-50% female 
employees across 
levels, and 30% in 
leadership roles
	• 3b. 30%-50% female 
employees in each 
country
	• 3c. Empower cultural 
diversity on a global 
level and introduce 
staff rotation
	• 3a. Female employees across levels 28%; 
One female promotion to manager through 
internal development
	• 3b. At least 1 female employee in each 
country: fulfilled in 2022 for USA, Japan, 
China, and India
	• 3c. Established strong relationships with the 
recruiters and worked on multicultural and 
gender-diverse talent acquisition: in total 
16 hires (8 different cultural backgrounds, 6 
female employees). Organised a workshop 
for a global Product Development team, 
FAE team, and Global Sales Meeting to 
enforce international exchange between 
different teams
	• 3a. Use social media and website to 
raise awareness that TASKING is 
supporting women in building their 
professional career 
	• 3b. Assess benefit packages 
regionally to provide flexibility and 
compensation for female employees 
and extend them when possible
	• 3c. Organise regular global meetings 
to support intercultural awareness 
– at least 4 (Marketing, Sales, FAE, 
Product Development)      
4. Employee 
happiness
	• 4a. Increase eNPS 
score
	• 4b. Development of 
our team 
	• 4c. ESG leadership
	• 4a. Increase eNPS 
score to 20+ and 100% 
employee participation 
in Winningtemp 
	• 4b. Performance 
reviews and 
development training 
offered across levels 
and departments 
globally  
	• 4c. ESG considered in 
all business decisions
	• 4a. Current eNPS score 17 (Nov 2022), 80% 
participation
	• 4b. Analysed and defined training topics 
across departments and organised first 
trainings/workshops, e.g., manager training, 
DevOps training, Global FAE workshop; 
Global Product Development workshop.
	- Implemented a regular Performance review 
and introduced it as part of the HRpuls 
tool; created an individual Development 
process for employees who were selected 
for promotion
	• 4c. Building up ESG initiatives as part of 
HR and company’s strategy through the 
cooperation with HR Contrast consultancy, 
ensuring that ESG topics are considered in 
all business decisions
	• 4a. Increase eNPS to 20 and 
increase the participation rate to 
90%
	• 4b. Ensure regular manager-em-
ployee performance dialogue once 
a year
	• 4c. Finalise HR strategy (taking into 
consideration  new acquisitions) 
and start with the first steps, 
including ESG topics
5. Ethical 
business 
conduct
	• 5a. ESG policies & 
control
	• 5b. Training for 
all employees 
covering topics 
such as ABC, CoC,  
Whistleblowing
	• 5c. Data security 
and privacy training
	• 5d. Resellers, 
partners, and 
customer 
compliance process 
documentation
	• 5a. ESG and whistle-
blower policies are 
regularly updated to 
follow best practice
	• 5b. All employees 
complete regular ESG 
training
	• 5c. All employees 
complete data security 
and privacy training 
with an assessment/ 
exam at the end
	• 5d. Best in class proce-
dures in compliance
	• 5a. 100% of new hires signed ESG policies
	• 5b. The onboarding process is ensuring 
that all new hires get familiarised with ESG 
policies through HR onboarding during 
their first week
	• 5c. Proceeded with the first Data Privacy 
and Data Security training for the EMEA 
team
	• 5d. Implemented DESCARTES Visual 
Compliance tool/Salesforce for automatic 
screening of all resellers and external 
partners on the implementation of a 
compliant processes
	• 5a. Implement and introduce an 
electronic Whistleblower channel;
	• 5b. Find a solution for an ESG 
eLearning and ensure 100% of 
employees complete training; 
Organise Compliance training with 
a focus on ABC for Sales reps
	• 5c. Organise regular Data Privacy 
and Data Security meetings on a 
global level and ensure 100% of 
employees complete the training
	• 5d. Continuously keep the same 
high level of the compliance process
TASKING'S ESG STRATEGY 2023 
TASKING has selected the following SDGs to which it has an opportunity to contribute:
Reduce global deaths and injuries from road traffic accidents (3.6)
FSN Portfolio Company since 2020
tasking.com
TASKING offers high-performance, embedded software development tools 
for original equipment manufacturers (OEMs) and Tier 1 suppliers in the 
automotive space.
Its strategic partnerships with semiconductor manufacturers, OEMs, 
and suppliers make TASKING a leading player in the embedded software 
development industry for safety relevant applications,  advanced driving 
assistance systems (ADAS), and autonomous driving.
Headquartered in Munich, TASKING is a global company with teams 
in Europe, Asia, and the US. TASKING is world-renowned for superior 
compiler technology. Its tools have been used for over 30 years by 
developers and the world’s leading organisations to meet the demands of 
specialised embedded software development.
TASKING's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 GHG emissions and energy use 
from purchased hardware 
∙	 Local emissions from mineral 
extraction (hardware)
∙	 E-waste and hazardous waste
∙	 Labour and human rights in 
hardware and raw material sourcing  
∙	 Workers’ health and safety
∙	 Socioeconomic impact of 
corruption and bribery in the 
supply chain
OWN
OPERATIONS
∙	 GHG emissions from  
own operations
∙	 Energy consumption
∙	 Water use own operations 
∙	 Sound pollution from data centres
∙	 Biodiversity impact at data centres  
∙	 Employee training and 
development 
∙	 Labour conditions and human 
rights for employees
∙	 Work-life balance 
∙	 Diversity and inclusion
∙	 Cyber security 
MANAGEMENT  
& MARKETING
 
∙	 Energy use in offices
∙	 Employee commuting and business 
travel 
∙	 Employee benefits and working 
conditions 
∙	 Diversity and inclusion
∙	 Anti-corruption and bribery 
∙	 Tax policies and payments 
∙	 Anti-competitive behaviour 
CUSTOMERS 
& END-USERS
∙	 Energy use after sales 
∙	 Streamlining of resource 
consumption of customers’ 
products
∙	 Climate impact of services in use 
∙	 Road safety 
∙	 Customer data privacy 
∙	 Product safety 
∙	 System reliability  
(lagging, down time)
∙	 Contract conditions 
∙	 Cyber security 
External factors impacting TASKING based on its sector, jurisdictions, 
and operations
	
+ Demand for products that enable road safety
	
+ Demand for products that enable a  reduction in GHG emissions 
when in use 
	- Requires highly specialised technical workforce
	- Heightened cyber attack risks globally, putting pressure on product 
security and system reliability
	- Geopolitical instability, and anti-bribery and corruption risks in high-risk 
jurisdictions
Initial EU taxonomy assessment
Key activities
∙	 J62.01 – Programming services
Potential contribution to environmental objective
∙	 Climate change mitigation (enabling)

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
104
105
FOCUS AREA
KPIS
LONG TERM TARGET
PERFORMANCE 2022
ANNUAL TARGET 2023
1. Improve 
climate  
resilience 
of the 
society
	• 1a. LCA 
calculation 
tool for each 
business unit 
(BU)
	• 1b. EPDs
	• 1c. ISO 14001
	• 1d. 
Emissions-free 
solutions
	• 1a. LCA calculation 
tool for key solutions in 
each BU
	• 1b. EPDs for all product 
categories
	• 1c. ISO 14001 certifica-
tions for all production 
units
	• 1d. Launch the first 
“emissions-free” soil 
steel bridge and water 
tank by 2028*
	• 1a. Initiative to combine LCA calcu-
lators for BU1 and BU2 started. BU3 
calculator expanded to take backfill 
into account.
	• 1b. BU1: EPDs covering 100% of 
products, 86% of EPDs certified by 
ITB. BU2: EPD’s covering 11 products.
	• 1c. Expanded ISO certifications to 
plant in France - ISO 9001, 14001, and 
45001"
	• 1d. Design sustainable bridge pilot 
identified and in progress
	• 1a. Environmental impact assessment added 
as a standard when offering ViaCon solutions.
	- Update of LCA Comparison Calculator.
	- Launch LCA calculator 2023.
	• 1b. BS1: Analyse EPD data from production 
units, understand differences, and reduce 
them.
	- BS2: EPD’s cover 50% of spending on traded 
goods suppliers; Complete EPD certificate 
for Plastic products in Romania, Poland & 
Lithuania.
	• 1c. Continue ISO group implementation
	• 1d. Continue to identify sustainable bridge 
pilot design
2. Become 
Net Zero 
	• 2a. Reduce 
GHG 
emissions 
	• 2b. EU 
taxonomy
	• 2a. Become Net Zero 
by 2050
	• 2b. To be defined
	• 2a. Scope 1 & 2 reported for 8 quarters.
	• Aligned Scope 3 with SBTI criteria.
	• Member of SteelZero initiative.
	• Committed to SBTI in November.
	• 2b. Started EU taxonomy alignment 
assessment
	• 2a. Submit SBTi target of -42% reduction in 
emissions by 2030.
	- Report 50% of spend as tonnage or with EPD 
rather than spend based within CEMAsys. 
	• 2b. Define Taxonomy alignment areas and 
establish eligibility.
3. Maximise 
material 
utilisation 
and 
recycling in 
production
	• 3a. Virgin 
plastic 
reduction
	• 3b. Steel raw 
material 
consumption
	• 3a. Reduce virgin plastic 
raw material in pipes by 
22% by 2025
	• 3b. Reduce steel 
consumption by 2.5% 
by 2025
	• 3a. 27.7% reduction in virgin plastic 
achieved – full potential achieved
	• 3b. Reduced steel consumption by 1%
	• 3a. Maintain virgin plastic reduction % 
	• 3b. Reduce steel consumption on water tanks 
with current mix from 1% in 2022 to 2% in 
2023
4. Be this 
industry’s 
preferred 
employer
	• 4a. eNPS
	• 4b. 
Engagement 
index (EI)
	• 4c. Lost days 
per 1000 
Employees
	• 4d. Employee 
turnover rate
	• 4e. Share 
female 
employees 
	• 4a. eNPS of 10 by 2025
	• 4b. EI of  >7.3 by 2025
	• 4c. Lost Days at <400 
in 2024
	• 4d. Employee turnover 
rate of <8% in 2023
	• 4e. Improved gender 
balance in our teams – 
target gender manager 
to employee ratio gap of 
<1% by 2026
	• 4a. eNPS currently at -7
	• 4b. Engagement index at 7.1 and 
Leadership Programs delivered to plan​
	• 4c. Days lost in 2022 were 515 vs. 582 
days in 2021 (12% improvement)
	- 8 Production sites were visited, and 
reports were developed
	- Near miss increased 107% YOY
	• 4d. Turnover rate: 9.7%​ Voluntary, 
4.9% Involuntary
	- Salary review done​
	- Performance appraisal implemented​
	- Employer branding partly completed​
	- Leadership development complete
	• 4e. Gender management diversity gap 
at 4.55%
	• 4a. Target of +1 eNPS for 2023
	• 4b. Target of 7.2 engagement index
	• 4c. 10% improvement in lost days
	• 4d. Voluntary Employee turnover of 8%
	- Build the ViaCon brand as a desirable 
employer through executing our Employer 
branding Program
	• 4e. Have a manager diversity ratio gap of less 
than 3.5% in 2023
5. Ensure 
business 
ethics
	• 5a. Business 
ethics/ CoC 
training
	• 5b. Suppliers 
and distrib-
utors signing 
CoC
	• 5c. Supply 
chain 
management
	• 5a. 95% of employees 
complete eLearning 
annually
	• 5b. 90% of suppliers and 
distributors to sign CoC
	• 5c. Best-in-class supply 
chain mgmt.
	• 5a. 97% of employees completed 
training
	• Redesigned and updated training for 
2023.
	• 5b. 78% of suppliers signed CoC; 75% 
of distributors signed CoC
	• 5c. Risk assessments completed on top 
35 suppliers
	• 5a. 95% of employees to complete updated 
eLearning
	• 5b. 90% of suppliers and distributors having 
signed CoC 
	• 5c. Complete risk assessments to cover 80% 
of company spend
 
* pending Green steel initiative
VIACON'S ESG STRATEGY 2023 
ViaCon has selected the following SDGs to which it has an opportunity to contribute:
ViaCon focuses on safe working environments, code of 
conduct and long-term employment
ViaCon creates value for our customers by providing them 
sustainable solutions tailored towards their specific needs
ViaCon invests in new and excisting plants and facilities to 
reduce emission from our own operations as well as from 
the use of our products. We focus on providing sustainable 
solutions, on recycling and training
ViaCon is a trusted partner to all our stakeholders with focus 
on sustainable solutions during all stages of our consumption, 
production, transport and utilisation
FSN Portfolio Company since 2018  
(first as part of Saferoad Group)
viacongroup.com
ViaCon provides mission-critical sustainable infrastructure products and solutions 
to customers across Europe, the Middle East, and North Africa. The company is 
organised into three business units (BU): 1) Bridges & culverts – consist of the 
design, engineering, manufacturing, and installation of corrugated steel structures 
and culverts; 2) Geotechnical – solutions used in a range of applications from soil 
reinforcement in infrastructure projects to solutions for groundwater protection in 
landfills; and 3) Stormwater – consists of the design, engineering, manufacturing, 
and installation of water management systems to manage flood water.
ViaCon employs ~800 people across 20 countries, with its main production 
plants being in Poland, Lithuania, France, the UK, and Turkey. The main raw 
materials are steel coils and raw plastic. Most geotechnical products are procured 
by suppliers. ViaCon often acts as a sub-supplier to construction companies that 
participate in larger public tenders for road and tunnel construction. Stormwater 
solutions are sold to B2B customers.
ViaCon's potential ESG impacts based on its sector, jurisdictions, and operations
Topics of higher importance in bold
RAW MATERIALS
& SUPPLIERS 
∙	 Energy consumption in raw 
material (steel, plastic) 
production
∙	 Greener produced raw materials 
(steel)
∙	 Water use in the supply chain
∙	 Biodiversity impact of raw material 
sourcing (steel, plastic)
∙	 Labour and human rights in the 
supply chain
∙	 Workers' health and safety in the 
supply chain
∙	 Supply chain transparency
∙	 Business ethics in procurement
OWN
OPERATIONS
∙	 Energy use at production sites
∙	 Hazardous waste at production 
sites
∙	 Water consumption at production 
sites
∙	 Emissions from in- and outbound 
logistics
∙	 Labour and human rights
∙	 Workers' health and safety
∙	 Anti-corruption and bribery
MANAGEMENT  
& MARKETING
 
∙	 Energy consumption in sales offices
∙	 Commute and business travel
∙	 Office waste (food from the 
cafeteria, stationary and paper)
∙	 Employee education and 
development
∙	 Diversity and anti-discrimination
∙	 Anti-corruption and bribery
∙	 Anti-competitive behaviour
CUSTOMERS 
& END-USERS
∙	 Product longevity and maintenance
∙	 GHG emissions from product 
installation
∙	 End-of-life: machine reuse, repair, 
recycling
∙	 Product and packaging waste 
occurring when installing
∙	 Product's interaction in nature
∙	 Partner and customer integrity
∙	 B2B contract condition
External factors impacting ViaCon based on its sector, jurisdictions, and operations
	
+ Demand for climate change mitigation solutions, e.g., products and 
services with lower CO2 emissions than alternatives
	
+ Demand for climate change adaptation solutions, e.g., solutions that 
mitigate flooding, ensure safe water, and reduce cross-contamination 
of water/wastewater
	- Scrutiny of the environmental impact of raw material sourcing, 
transportation, and production
	- Anti-corruption and bribery risks in key markets
	- Human and labour rights concerns associated with higher-risk markets 
Initial EU taxonomy assessment
Key activities
∙	 3.6. Manufacture of other low carbon technologies.
∙	 9.1. Engineering activities and related technical consultancy 
dedicated to adaptation to climate change.
Potential contribution to environmental objective
∙	 Climate change adaptation
∙	 Climate change mitigation (enabling)

CHAPTER 3 — ESG Developments in FSN Portfolio Companies
FSN Capital ESG Report 2022
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107
FSN Portfolio Company since 2022
baeckergoertz.de 
Newly acquired 
Bäcker Görtz is a leading bakery chain in the 
Rhine-Neckar region in South-West Germany. With 
a network of approximately 200 branches, it offers 
a tailored product assortment of baked goods and 
out-of-home meals. Bäcker Görtz was founded and has 
been owned by the Görtz family since 1963, with many 
employees having been part of the company for over a 
decade. 
Bäcker Görtz places high importance on regional 
and local sourcing leading to an almost entirely 
Germany-focused value chain centralised around its 
state-of-the-art production site at its headquarter 
in Ludwigshafen, Germany. Bäcker Görtz provides 
affordable meals to approximately 100,000 customers 
per day, comprising residents as well as visitors of the 
South-West Germany region spanning all age groups 
and professions.
Acquired in Q4 2022 - ESG analysis completed;  
yet to fully develop ESG strategy

CHAPTER 4 — Internal ESG initiatives and reporting
FSN Capital ESG Report 2022
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109
CHAPTER 4
Internal ESG 
Initiatives and 
Reporting
How FSN Capital works with ESG internally, 
and our performance against industry initiatives 
and regulatory reporting requirements

CHAPTER 4 — Internal ESG initiatives and reporting
110
111
FSN Capital's Culture
We strive to pursue a performance culture that radiates 
integrity and trust. To underpin this culture, we have 
developed three core values which are nothing but 
codified behaviour.  
For more information, see fsncapital.com/values
GROWTH MINDSET
The belief that you can always improve, the courage to set bold, visionary goals, and the desire and 
grit to overcome the barriers that stand in the way of winning.
•	
We gaze for the stars
•	
We face the brutal facts
INTEGRITY
The quality of knowing, and having the personal strength to do what is morally right, even 
when no one is watching or there appears not to be a benefit in the short term.
•	
We are decent people
•	
We are purpose-driven
TEAM FIRST
Putting the team ahead of ourselves to maximise performance and win together.
•	
We build trust
•	
We promote diversity of thought	
	
•	
We thrive on Positive Dissatisfaction
•	
We insist on excellence,  
and nothing less
•	
We act with courage
•	
We focus on the long-term
•	
We dare to challenge
•	
We win together
We have three core values:

CHAPTER 4 — Internal ESG initiatives and reporting
FSN Capital ESG Report 2022
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113
BUILD DIVERSE 
INVESTMENT AND 
BUSINESS SERVICES 
TEAMS
% of new hires are diverse1
% female Executive Advisors
% female board members across all 
portfolio companies2
% of portfolio company 
boards that are diverse3
BUILD A DIVERSE 
EXECUTIVE ADVISOR 
NETWORK AND BOARD 
OF DIRECTORS
1.	
In terms of gender, ethnicity or educational/professional background compared to the team you are hired into (i.e. a male is considered diverse if hired into a 
female-dominated team) – no double counting
2.	 Female board members to total board members (excludes minority shareholders, FSN Capital employees, and employee representatives)
3.	
At least one female and one international board member – no double counting
DIVERSITY & INCLUSION TARGETS
% of due diligence teams used by 
FSN Capital having 25% female 
members
2022 status
2021 status
2023 goal
FSN Capital’s*…
2016
2017
2018
2019
2020
2021
2022
Employees (FTEs)
32
39
48
51
53
68
72
Representation of women 
(% FTEs)
28%
28%
33%
33%
36%
41%
39%
Representation of women on 
investment team 
4%
7%
9%
14%
21%**
30%
25%
Employee Satisfaction 
(eNPS)
92
79
46
60
66
80
65
 
*Numbers as of 31.12 each calendar year, Interns not included​
**Correction from 2021 ESG report
HISTORICAL PEOPLE PERFORMANCE
33%
50%
100%
71%
30%
30%
23%
75%
100%
68%
55%
50%
100%
73%
67%
66%
Diversity, Equity & Inclusion
In an increasingly complex world, having teams with 
complementary skillsets and backgrounds is vital for 
success. FSN Capital places significant emphasis on 
diversity, equity, and inclusion (DEI).
To further improve in this area, a firmwide DEI 
initiative has been launched, focused on accelerating 
our efforts and creating a DEI strategy which reflects 
our values and cultural DNA. The initiative is building 
on our successful Team First approach including 
cross functional working groups to research, discuss, 
and propose practical recommendations to be 
implemented.
The project is guided by a Steering Group 
including internal and external contributors from 
diverse offices, tenures and functions to promote 
diverse thinking and perspectives.
Based on input from all Steering Group members, 
the following areas were defined as focus areas for the 
working groups:
	·
Defined clear targets for improvement: 50% of 
all new hires to the investment team, Executive 
Advisors and portfolio company board of 
directors should be female
	·
Partnered with headhunters specialised in 
recruiting female candidates to help us achieve 
the goal
	·
Cooperation with Equality Check (formerly 
#ShesGotThis) since 2017
	·
Cooperation with MAK, a network for young 
professionals promoting intercultural and 
ethnic diversity
	·
Part of the Nordic Executive Committee of 
Level20
	·
Unconscious bias training conducted for the 
Partner Group and all employees
	·
Mentoring program for all women in the 
investment team, where they are paired with 
external female senior executives
	·
Generous parental leave offerings for all team 
members
	·
Included gender diversity on portfolio company 
boards as one of three KPIs in the  
sustainability-linked subscription facility for 
FSN Fund VI
	·
Signed the CEO Commitment
Activity
	·
Talent & Recruitment
	·
Career Opportunities
	·
Career Development & Learning
	·
Parenting
	·
Work Conditions
	·
Teamwork and Collaboration
Behavioural
	·
Culture & Communication
	·
Leadership
	·
Unconscious Bias
	·
Accountability & Success
Each working group will define their own process 
finishing by end of 2023 where each group is to present 
and summarise key recommendations for improving 
FSN Capital’s DEI strategy within their topic.
SOME OF THE DEI MEASURES TAKEN TO DATE INCLUDE:

CHAPTER 4 — Internal ESG initiatives and reporting
FSN Capital ESG Report 2022
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115
FSN Capital’s Internal 
Climate Footprint
FSN Capital has targets verified by the SBTi and has 
committed to Net Zero. Although total emissions per 
employee decreased in 2022 by 23% from 2019, our 
total absolute emissions were above pre-pandemic 
levels, and we will work on reducing our emissions 
further. 
In addition to reducing our emissions, we each 
year offset any remaining emissions by buying carbon 
removal credits.  Total emissions for FSN Capital in 
2022 was 406 tons CO2e, and we bought Verified 
Carbon Standard (VCS) credits for planting of 
mangrove trees and reforestation1. These credits are in 
line with SBTi's carbon removal strategy.
GHG EMISSIONS FOR FSN CAPITAL2 (tCO2e)
2019
2020
2021
2022
% Change from 
2019 baseline
Scope 1
  
  
  
  
  
Transportation
4.3
4.3
4.6
5.9
 
Total Scope 1
4.3
4.3
4.6
5.9
37.2%
Scope 2 (market-based)
 
 
 
 
 
Electricity 
51.5
45.7
29.1
39.6
 
District heating
3.7
4.6
4.4
2
 
District heating (general)
10.2
10
9.8
0
 
Total Scope 2 (market-based)
65.4
60.3
43.3
41.6
-36.4%
Scope 1+2 emissions (market-based)
69.7
64.6
47.9
47.5
-31.9%
Scope 3
 
 
 
 
 
Waste
2
1.8
1.8
4
 
Business travel
303.5
69.8
52.5
354.7
 
Total Scope 3
305.4
71.6
54.3
 358.6
17.5%
Scope 1+2+3 total emissions (market-based)
375.1
136.2
102.2
406.2
8.3%
Total Scope 2 (location-based)
23.2
21.2
18.8
7.8
-66.4%
Scope 1+2+3 total emissions (location-based)
332.9
97.1
77.7
372.4
11.9%
 FSN Capital employees (FTEs)
 51
 53
 68
 72
 41.2%
Business travel/employee 
6.0
1.3
0.8
4.9
-17.2%
Total emissions/employee (market-based)
7.4
2.6
1.5
5.6
-23.3%
SBTI APPROVED 
EMISSIONS TARGETS
Reduce absolute direct emissions (scope 1  
and 2) by 60% by 2026, from a 2019 baseline
Reduce absolute emissions from business  
travel and waste (scope 3) by 29% by 2026, 
from a 2019 baseline
STATUS 2022
-32% 
from 2019 baseline
+18% 
from 2019 baseline
COMMENTARY
On track to meet SBTi target
Business travel main driver for increase.  
FSN Capital to revisit travel policy. Note 
that number of employees in FSN Capital has 
increased, and emissions from business travel 
per employee has dropped by 17% since 2019
1.	
There is no guarantee that projects will be completed and/or result in actual emissions reductions
2.	 GHG emissions based on activity data, except waste which is estimated by CEMAsys in line with the GHG Protocol

CHAPTER 4 — Internal ESG initiatives and reporting
FSN Capital ESG Report 2022
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117
RISK
MANAGEMENT
Under FSN’s Climate Framework, climate-related risks are identified and assessed 
as part of the due diligence process as well as part of the annual review of a portfolio 
company’s ESG strategy.  
Climate-related risks are managed as part of a portfolio company’s ESG strategy to 
the extent relevant, and by ensuring that all portfolio companies measure, report and 
set targets to reduce their greenhouse gas emissions in line with the Paris Agreement. 
FSN’s ESG approach, including the FSN Climate Framework, is an integral part of 
FSN’s due diligence, onboarding and ownership approach. 
METRICS
& TARGETS
As part of FSN Capital’s validated Science Based Targets, FSN Capital commits to:
	·
Reduce own absolute Scope 1 and Scope 2 GHG emissions by 60 % by 2026 from a 
2019 base year;
	·
Reduce own absolute Scope 3 (cat.5, waste, and cat. 6, business travel) GHG 
emissions by 29% by 2026 from a 2019 base year; and
	·
That 60% of FSN’s portfolio companies will have set SBTs in 2026 and 100% by 
2030 from a 2020 base year.
FSN Capital’s greenhouse gas emissions are reported in line with the GHG 
Protocol, and status towards targets is set out on page 114. 
Climate-related metrics are included in the sustainability-linked financing facility 
of FSN Fund VI as further described on page 18 & 120.  
FSN portfolio companies are also required to report greenhouse gas emissions in 
line with the GHG Protocol. Please see  page 55 for reported numbers, status towards 
reporting of full scope as well as number of portfolio companies committed to the SBTi. 
Other company specific climate-related metrics are included in each portfolio 
company’s ESG strategy to the extent relevant. Please see Chapter 4 for each of the 
portfolio companies’ ESG strategies. 
LOW-CARBON  
TRANSITION PLAN
	·
FSN Capital was part of a working group, comprised of six private equity firms, that 
contributed to the development of the Science Based Targets initiative’s tailored 
guidance for the private equity industry, launched in 2021.
	·
FSN Capital has validated SBTs and is committed to Net Zero through NZAM.
	·
FSN Capital has as further described on page 114 purchased carbon removals for 
the last three years – and will continue to support planting of mangrove trees and 
reforestation also going forward.
	·
FSN Capital focuses on reducing its own greenhouse gas emissions and will in 2023 
review its travel policy to ensure further reduction.
	·
FSN Capital will continue to ensure progress on our commitments – page 4 & 114.
	·
FSN Capital will continue to support FSN portfolio companies on their journey 
towards SBTs. 
TCFD – FSN Capital
GOVERNANCE
The GP boards of each of the FSN Capital funds is responsible for management of the 
respective FSN Funds. FSN Capital Partners is the Investment Advisor to the FSN 
Capital funds. ESG strategy and execution, which includes climate-related risks and 
opportunities, is reviewed at least annually.  
FSN has developed the FSN Climate Framework (see page 42 for further details) to 
ensure appropriate consideration of climate-related risks and opportunities is included 
throughout the lifecycle of an investment. 
FSN Capital’s deal teams are responsible for applying the FSN Climate Framework 
both in the due diligence and ownership phase. 
FSN requires all portfolio companies to apply the FSN Climate Framework, but the 
ultimate decision and responsibility for this lies with the portfolio company board and 
management. 
FSN Capital’s ESG team develops FSN's standard approach to managing climate- 
related risks and opportunities and supports deal team and portfolio companies in 
applying these.  
STRATEGY
FSN Capital is a Northern European private equity firm, and the FSN Funds make 
control investments in growth-oriented Northern European companies, to seek to 
transform companies into more sustainable and resilient entities. 
As part of a wider climate strategy, FSN Capital has both set Science Based Targets 
and committed to Net Zero by joining NZAM.  
Taking short-term climate-related risks and opportunities (typically regulatory and 
market-based) into consideration in the ownership period is part of ensuring that a 
portfolio company is attractive for the next owner (medium-term) and stays relevant in 
the future by being committed to Net Zero operations (longer-term).   
Climate-related risks and opportunities affect both what type of investments FSN 
views as attractive and how FSN work with portfolio companies during the ownership 
phase. 
Under FSN’s Climate Framework, climate-related risks and opportunities 
(short-term, medium-term, and long-term risks) and a company’s resilience in different 
climate scenarios (including 2 degree or lower) are identified in the due diligence 
process and included in a portfolio company’s ESG strategy to the extent relevant.  All 
FSN portfolio companies will need to have validated SBTs by 2030, and a standard 
process to support portfolio companies on this journey is included in the FSN Climate 
Framework.

CHAPTER 4 — Internal ESG initiatives and reporting
FSN Capital ESG Report 2022
118
119
GOAL
TARGET
OUR OPPORTUNITY TO 
CONTRIBUTE
KPI AND 2022  
PERFORMANCE
	· 5.5. Ensure women's full 
and effective participation 
and equal opportunities for 
leadership at all levels of 
decision-making in political, 
economic and public life
	· Opportunity to include women on boards 
of directors and key C-suite positions, 
both in our portfolio companies and at 
FSN Capital
	· We track and encourage portfolio  
company diversity
	·  30% female board members across all port-
folio companies*
	·  30% of FSN Capital’s Executive Advisors are 
women
	· Sustainability-linked subscription facility 
with KPI on board diversity in portfolio 
companies
	· See p. 120 on Diversity for more information
	· 8.2. Achieve higher levels 
of economic productivity 
through diversification, 
technological upgrading and 
innovation, including through 
a focus on high-value added 
and labour-intensive sectors
	· Job creation through organic growth in 
the portfolio companies 
	· Opportunity to increase health and safety 
of the people working across the full value 
chain of our portfolio companies
	· 19 891  people employed by FSN portfolio 
companies
	· 6% increase in FSN Capital employees in 
2022
	· 13.3 Improve education, 
awareness-raising and human 
and institutional capacity on 
climate change mitigation, 
adaption, impact reduction 
and early warning
	· Opportunity to invest in companies that 
contribute to climate change mitigation 
and/or adaptation
	· Opportunity to reduce climate impact  
by providing tools and resources to report  
and reduce GHG emissions 
	· Increase climate awareness among 
portfolio companies and FSN Capital’s 
employees through strategy development 
discussions and trainings 
	· 23/25 of portfolio companies report GHG 
emissions
	· 5 FSN portfolio companies have committed 
to SBTi 
	· Climate change due diligence completed 
ahead of every transaction
	· Sustainability-linked subscription facility 
with KPIs on GHG reporting by portfolio  
companies
	· Carbon offsetting FSN Capital
	· 16.5 Substantially reduce 
corruption and bribery in all 
their forms
	· Opportunity to strengthen ethical busi-
ness conduct by always  
conducting an ESG due diligence and 
implementing the FSN Capital ESG Gov-
ernance Framework in our  
portfolio companies
	· 100% of FSN Capital employees have com-
pleted the mandatory e-Learning
	· 96% of Portfolio Companies have  
implemented the FSN Code of Conduct
	· 48% of Portfolio Companies have  
implemented Code of Conduct training
	· 92% of Portfolio Companies have  
implemented the FSN Standard Supply 
Chain Code of Conduct
	· 96% of portfolio companies have  
adopted the FSN Whistleblower policy
	· 84% of portfolio companies have  
adopted a Whistleblower system
UN SDGs
* Female board members to total board members (excludes minority shareholders, 
FSN Capital employees, and employee representatives)
The private sector plays an integral part in solving the 
most urgent global challenges, best described by the 
UN Sustainable Development Goals (SDGs). 
Since 2017, the UN SDGs have been part of  
how we engage with portfolio companies on ESG. 
Similarly, for our firm, we have identified the below 
SDGs and targets to which FSN Capital  
can contribute.
THE PRINCIPLES
EXAMPLES OF HOW FSN CAPITAL  
UPHOLDS EACH PRINCIPLE
1
We will incorporate ESG issues into the investment analysis and 
decision-making process
ESG and climate considerations are always included  
in the pre-investment phase and in the investment decision (see page 
32 & 36)
2
We will be active owners and incorporate ESG issues into our 
ownership policies and practices
We engage with our portfolio companies, providing them with ESG 
frameworks to support them in identifying material ESG issues 
and addressing these through ESG strategies (see page 30-36). The 
sustainability-linked subscription facility is designed to further 
incentivise implementation of our ESG frameworks in the ownership 
phase (see page 18, 38-43, & 120)
3
We will seek appropriate disclosure on ESG issues by the entities 
in which we invest
Portfolio companies are required to disclose material ESG issues in 
their value chain, their ESG strategy (see chapter 3), as well as FSN 
Capital standard ESG KPIs (see page 52)
4
We will promote acceptance and implementation of the
Principles within the investment industry
Our Responsible Investment Policy forms part of our formal commit-
ment to our investors. ESG questions are included in the annual service 
provider assessment conducted by FSN Capital. We collaborate with 
industry peers (see page 22)
5
We will work together to enhance our effectiveness  
in implementing the Principles
We share our ESG approach in relevant fora and contribute to sector 
ESG initiatives and events (see page 25)
6
We will each report on our activities and progress towards 
implementing the Principles
FSN Capital’s PRI transparency reports are publicly available on UN 
PRI’s websites
UN PRI
Compliance with the six principles of the UN 
Principles for Responsible Investment (PRI) is a 
natural part of our investment approach and the 
foundation for our Responsible Investment Policy. 
We welcome how PRI continues to drive the 
responsible investing agenda. Below we have 
highlighted some of our key efforts to fulfill our 
commitments under each PRI principle.

CHAPTER 4 — Internal ESG initiatives and reporting
FSN Capital ESG Report 2022
120
121
We have a sustainability-linked subscription facility linked to 
implementation of our ESG Frameworks in Fund VI portfolio 
companies (the FSN ESG Frameworks are further described 
in Chapter 2). Per the performance below, Fund VI achieved 
its KPIs targets for the year end 2022.
* Excludes investments where FSN Fund VI is a minority shareholder, i.e., Obton and Koncenton
** Female board members to total board members in Fund VI (excludes minority shareholders, FSN Capital employees, and employee representatives)
KPIs to be achieved by Dec 31st 2022 or earlier
KPIs to be achieved from 2023 and onwards
AS OF 31.12.2022 
Sustainability-Linked Subscription 
Facility for FSN Fund VI
KPI metric
Portfolio company*
Omegapoint
Closed June 
2021
MEGABAD
Closed 
August 2021
Adragos Pharma
Closed 
September 2021
OptiGroup
Closed March 
2022
Active Brands
Closed April 
2022
Aggregate 
results
KPI 1a
ESG Strategy & 
Climate Assessment
Yes (see p.88)
Yes (see p.82)
Yes (see p.60)
Yes (see p.90)
Yes (see p.58)
KPI achieved
KPI 1b
ESG Ownership
Yes
Yes
Yes
Yes
Yes
KPI achieved
KPI 1c
ESG Board Meeting 
Status Report
Yes
Yes
Yes
Yes
Yes
KPI achieved
KPI 2a
GHG System
Yes
Yes
Yes
Yes
Yes
KPI achieved
KPI 2b
GHG Emissions 
Scope 1 & 2
Yes
Yes
Yes
Yes
Yes
KPI achieved
KPI 2c
GHG Emissions 
Scope 3
Partly 
reporting
Partly 
reporting
Partly 
reporting
Partly 
reporting
Yes
KPI achieved
KPI 2d
GHG Emissions 
Target
Not yet
Yes (SBTi 
target)
Not yet
Not yet
Yes (SBTi 
target)
KPI achieved
KPI 3
Diversity Ratio KPI
7/17 professional board members are women = 41%**
KPI achieved

CHAPTER 5 — Appendix
FSN Capital ESG Report 2022
122
123
CHAPTER 5
Appendix
A collection of some of our governance policies, 
built on international conventions, standards 
and guidelines

CHAPTER 5 — Appendix
FSN Capital ESG Report 2022
124
125
3.	 We seek appropriate disclosure on ESG risks and 
opportunities by the entities in which we invest. 
4.	 We promote acceptance and implementation of 
the UN PRI within the investment industry. 
5.	 We work together to enhance our effectiveness in 
implementing the Principles. 
6.	 We will each year report on our activities and 
progress towards implementing UN PRI by 
completing the annual PRI signatory survey.
FSN Capital’s exclusion criteria
FSN shall not invest in assets that:
1.	 Have contributed to systematic denial of human 
rights.
2.	 Demonstrate a pattern of non-compliance with 
environmental regulations.
3.	 Show a pattern of engaging in child labour or 
forced labour.
4.	 Have an unacceptably high greenhouse gas 
footprint and have failed to take reasonable steps 
to reduce these emissions. 
5.	 Produce weapons that through their normal use 
may violate fundamental humanitarian principles 
(eg Anti-personnel landmines, Production of 
cluster munitions, Production of nuclear arms).
6.	 Are directly related to the following industries:
	·
Adult entertainment
	·
Tobacco
	·
Gambling
	·
Alcohol
FSN Capital Partners’ annual ESG report
FSN Capital has published an annual ESG report since 
2014. 
We will continue to publish an annual ESG report 
to transparently report on the progress of both FSN 
Capital Partners and the Portfolio Companies. 
In the annual ESG report we will describe in more 
detail how ESG is integrated in our investment process 
and ownership approach, as this naturally evolves over 
time. 
This policy will be reviewed and amended as 
appropriate from time to time.
Revised March 2021
Responsible Investment Policy  
for FSN Capital Partners
We are decent people seeking to make a 
decent return in a decent way. 
FSN Capital seeks to act with the highest level of 
integrity, taking a responsible approach when inter-
acting with our portfolio companies, our advisors, our 
investors, local communities, and the environment. 
FSN Capital publishes an annual ESG report to be 
transparent about our performance and keep ourselves 
accountable. 
With our investment approach, FSN Capital 
doesn’t see a need for a responsible investment policy 
that is treated separately from our general investment 
strategy. Our policy for responsible investments and 
our investment philosophy are intertwined and in fact 
two sides of the same coin; tools we apply to ensure 
that we over time get the best possible combination of 
controlling risk and enhancing value.
Compliance with UN’s Principles for 
Responsible Investment (UN PRI)
UN PRI promotes integrating ESG perspectives into 
the investment process and active ownership policy. 
For FSN Capital, being a signatory falls naturally 
within our investment approach and being compliant 
with these six UN PRI principles is a natural part of an 
investment strategy to safeguard and enhance return 
of our portfolio investments:
1.	 We always incorporate ESG risks and opportu-
nities into the investment analysis and decision-
making process.
	·
This Responsible Investment Policy defines our 
formal exclusion criteria. 
	·
We conduct a climate change due diligence in 
every transaction.
	·
We conduct an ESG due diligence in every 
transaction. 
	·
A summary of the key risks and opportunities 
identified in the climate and ESG due diligence 
is always included in the investment decision 
material. 
	·
We always consider the likely impact of key 
sustainability risks on return by having ESG risks 
integrated in our Risk Framework.  
2.	 We are active owners and incorporate ESG into 
our ownership policies and practices.
ESG is a core part of FSN Capital Partners’ value 
creation approach. 
We implement both the FSN Capital Governance 
Framework and the FSN Capital ESG Strategy 
Framework in every Portfolio Company. With the FSN 
Capital Governance Framework we set the tone from 
the top and have minimum requirements with regards 
to ESG policies, implementation of ESG policies, 
and governance. The FSN Capital ESG Strategy 
Framework is our method for establishing an individ-
ualised ESG strategy for each Portfolio Company.
As responsible owners, we are dedicated to 
continuing to push the frontier of what constitutes 
good ESG governance. Our ESG Frameworks will 
therefor evolve over time in line with international 
conventions, standards, and guidelines.

CHAPTER 5 — Appendix
FSN Capital ESG Report 2022
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127
Whistleblower policy
If anyone in FSN Capital Partners becomes aware of 
circumstances that violates laws, regulations or the 
Code of Conduct, they are encouraged and sometimes 
obligated to report this. We encourage employees 
to make good faith reports of actual or suspected 
breaches of our Code of Conduct, and no one who in 
good faith reports a violation shall suffer retaliation 
from FSN Capital Partners or other employees. In 
most cases, an employee’s sponsor or the head of 
relevant local FSN Capital Partners’ office is in the 
best position to address an area of concern. If this 
reporting channel is deemed inappropriate, please see 
contact list below:  
Head of ESG and Compliance Officer FSNC
Rebecca Svensøy
Head of Compliance - Chairperson FSNC
Frode Strand-Nielsen 
Co-Managing Partner FSNC
Robin Mürer
Co-Managing Partner FSNC
Ulrik Smith
External contact person
Gunnar Holm Ringen at PwC 
We expect that all employees are familiar with our 
Code of Conduct and actively promote its content.
FSN Capital Partners’ Code 
of Conduct – short version
WE ARE DECENT PEOPLE MAKING A 
DECENT RETURN IN A DECENT WAY  
Purpose and main principle 
The purpose of the Code of Conduct is to create a 
company culture that promotes integrity, our values, 
ethical guidelines and the FSN Capital Partners’ 
policies. The underlying principle for the Code of 
Conduct is that we always do the right thing, and if we 
are unsure, ask people who might know first.  
The Code of Conduct applies to everyone in FSN 
Capital Partners, including all direct and indirect 
subsidiaries, and we expect all Board members, 
Advisors and Employees to live by them. 
 Always 
Never 
	
+
Act professional and treat others with respect 
	
+
Be careful when writing or posting pictures in 
blogs and social media regarding FSN Capital 
Partners, suppliers or customers 
	
+
Comply with applicable laws and regulations, 
including sanctions and export laws 
	
+
Act to promote a culture characterised by 
respect, inclusion, equality and diversity 
	
+
Act in the best interest of FSN Capital Partners 
at all times 
	
+
Avoid conflict of interests and disclose all actual 
or potential conflict of interest to your line 
manager  
	
+
Follow regulations regarding insider information 
and the insider list 
	
+
Compete fairly within the framework of relevant 
antitrust and competition laws 
	
+
Act in a socially responsible manner that is safe 
and protective to people, the environment and 
society 
	
+
Promote principles set out in international 
conventions regarding human rights and worker’s 
rights 
	-
Do not conduct any form of harassment, 
discrimination or treatment that may be interpreted 
as threatening or degrading by others 
	-
Do not discriminate or provide differential treatment 
to others 
	-
Do not share any confidential information 
	-
Do not conduct any form of corruption – this 
includes offer, promise, request, demand, receive 
or accept unlawful or inappropriate gifts or other 
remunerations (all employees will be provided 
training in this) 
	-
Do not give or accept gifts, entertainment or 
preferential treatment unless: 
	-
it is a non-cash gift 
	-
it is consistent with customary business practice 
	-
it is of insignificant value 
	-
it cannot be construed as a bribe or kickback 
	-
it is in accordance with FSN Capital Partners 
values 
	-
it does not violate any laws 
	-
Do not exploit children as a labour force 
	-
Do not exploit any form of forced or compulsory 
labour 
	-
Do not breach or circumvent any international 
sanctions regimes

CHAPTER 5 — Appendix
FSN Capital ESG Report 2022
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129
​All leaders and managers, regardless of country 
or location, are responsible for setting the right tone 
at the top to cultivate a strong corporate culture for 
ethics and compliance. They are expected to act as 
role models for ethical conduct, educate and support 
employees in complying with the Code and underlying 
policies, perform oversight to detect violations, 
identify and mitigate compliance risks, and finally yet 
importantly, promote a culture of speaking up in good 
faith without fear for retaliation.​ 
​Employees are responsible for seeking advice 
when in doubt regarding any of the topics in the Code.​ 
2. Laws and Regulations  
​All board members and employees are personally 
responsible for complying with applicable laws, 
regulations and guidelines issued by public author-
ities, and compliance shall always prevail over our 
business goals and needs​.
​It is also our policy to respect the principles set 
out in the UN Global Compact as attached hereto 
as Appendix A, (principles derived from the UN 
Convention against Corruption, the UN Declaration of 
Human Rights, the ILO Declaration on Fundamental 
Principles and Rights at Work and the Rio Declaration 
on Environment and Development), the OECD 
guidelines for corporate governance for multilateral 
enterprises and the UN Convention on the Rights of 
the Child.​ 
​Where differences exist between applicable laws, 
regulations and our Code and underlying policies, the 
highest standard of behaviour shall always prevail.  ​
Furthermore, employees must not engage in activities, 
even if legal, that could harm the reputation of FSN 
Capital. If you are unsure about what is acceptable, 
please seek advice.​ 
3. Work environment and safety  
FSN Capital shall provide a professional, inspired 
and safe workplace in accordance with mandatory 
legislation and will show respect for all individuals 
and make active efforts to ensure a good and inclusive 
working environment characterised by equality and 
diversity. ​A healthy workforce contributes to stronger 
and safer performance in the workplace. ​ 
FSN Capital’s suppliers ​ar​e required to apply the same 
principles. 
No form of harassment, discrimination, differential 
treatment or other conduct which may be interpreted 
as threatening or degrading​ shall ever be permitted​​ 
4. Conflicts of interest 
Board members and employees must behave 
impartially in all business dealings and not give other 
individuals, companies or organisations improper 
advantages. Everyone shall avoid situations where 
conflicts of interest may arise between their personal 
and/or financial interests and those of FSN Capital or 
any of the FSN Capital Funds.  
No one must work on or deal with any matter in 
which they themselves, their spouse, partner, close 
relative or any other person with whom they have a 
close relationship, has a direct or indirect financial 
interest. Further, the same applies when special 
circumstances exist which may weaken the perceived 
impartiality or the trust and integrity of employees or 
of their work. 
Employees who consider themselves not to be 
impartial in relation to any particular matter, or who 
are uncertain as to their impartiality, shall notify their 
sponsor or point person of their situation and may 
then be excused from having any further involvement 
in the matter concerned.  
FSN Capital Partners’ 
Code of Conduct
INTRODUCTION  
Our ethos reads “We are decent people making a 
decent return in a decent way”.  
Integrity and honesty are at the heart of who we 
are. We maintain high ethical standards in everything 
we do and take pride in living by these standards, both 
in our professional and personal lives.  
We believe that FSN Capital has three assets – 
people, capital and reputation. If any of these are 
ever compromised, reputation is the most difficult 
one to restore.  Reputation takes years to build, but 
only one wrong act  to ruin.​ Each and all of us at 
FSN Capital have a responsibility to act with utmost 
integrity. Doing what is right is our North Star, 
even when it may be against short-term business or 
personal interest.. Be mindful that how we behave 
in our private life may also pose a reputational risk 
to the firm.  Clear requirements and consistent 
business conduct build trust and loyalty among 
employees, business partners, investors, customers 
and communities​ 
The purpose of this Code of Conduct is to breathe 
life into the definition of who we are and what we 
stand for, and to inspire and steer our team members, 
Executive Advisors and portfolio companies to do the 
right thing every day – even when no one is looking. 
A breach of law​s or regulations,​ or of our Code of 
Conduct is a threat to our Firm’s culture, our compet-
itiveness and our reputation. We strive, therefore, to 
ensure that we do not compromise our ethos, integrity 
or values and that every member of the FSN Capital 
team is encouraged to raise the following question if 
in doubt: “Is this behaviour in line with our ethos and 
values?”  
CODE OF CONDUCT FOR FSN CAPITAL  
Ethics deals with ideas about what is right and wrong. 
We believe that ethics in professional life must be 
directly linked to the ethics that set the standards for 
us as individuals and as a society. Combining ethical 
judgement with personal strength to act out that 
judgement is our definition of integrity.  
1. Personal Conduct  
FSN Capital sets high ethical standards for everyone 
who acts on behalf of the Firm. All board members 
and employees must conduct themselves with 
courtesy, respect and integrity in business relation-
ships, towards customers, colleagues and others who 
they encounter in professional life. ​
​All board members and employees must protect 
FSN Capital’s assets to ensure that they are used 
efficiently and properly for legitimate business 
purposes. Each employee is personally accountable for 
the use of any Firm assets which he or she controls. 
Incidental personal use of telephones, copy machines, 
personal computers and similar equipment is allowed 
provided that there is no significant cost to the Firm, it 
does not interfere with duties to the Firm, and it is not 
related to any illegal activity or is otherwise outside 
the Firm’s business activity. 
FSN Capital team members must not use assets 
of the Firm or the FSN Capital Funds directly or 
indirectly for contributions of any kind to any political 
party, political committee or candidate for, or holder 
of, any public office. Board members and employees 
may participate in political activities solely in their 
personal capacity and never in the capacity of being 
an employee or representative of FSN Capital, and 
always with due consideration to FSN Capital’s Code 
of Conduct.

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FSN Capital ESG Report 2022
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131
9. Anti-corruption and fraud​: 
Remuneration and gifts
FSN Capital is strongly opposed to all forms of 
corruption​ and fraudulent behaviour​. Corruption ​and 
fraudulent behaviour ​undermines legitimate business 
activities, distorts competition, ruins reputations and 
exposes companies and individuals to risk.  
FSN Capital makes active efforts to ensure that 
corruption​ and fraud​ does not occur in its business 
activities.  
The purpose of entertainment and gifts in a 
business setting is to create and enhance goodwill and 
working relationships to better serve the FSN Capital 
Funds and their investors, and not to gain an unfair 
business advantage. 
No Executive Advisor and no one at FSN Capital 
shall offer, promise, request, demand, receive or accept 
unlawful or inappropriate gifts or other remuneration. 
In some countries, “facilitating” (paying a “small 
token” to smooth a process or transaction) is not 
uncommon, but FSN Capital does not accept this as a 
way of doing business. 
No one shall gain personal business-related 
benefits other than gifts or services of insignificant 
value.  
FSN Capital Partners’ policy for gifts is as follows: 
a.	 No gift, entertainment or preferential treatment 
can ever be solicited, provided or accepted by any 
individual at FSN Capital unless (i) it is a non-cash 
gift, (ii) it is consistent with customary business 
practices, (iii) it is of insignificant value, (iv) it 
cannot be construed as a bribe, payoff or kickback, 
(v) is in accordance with FSN Capital’s ethos and 
(vi) it does not violate any laws; 
b.	 All directors and employees of FSN Capital 
shall notify the Compliance Officer of any gifts, 
entertainment or preferential treatment prior to 
such being provided or accepted. The Compliance 
Officer shall maintain a gift-log and approve gifts, 
entertainment or preferential treatment only 
when such are in compliance with FSN Capital’s 
anti-corruption policy set out herein;  
c.	 As a general rule, one should decline invitations 
to paid events or trips hosted by service providers 
or other business contacts. Participation at paid 
events must always be authorised by FSN Capital’s 
Compliance Officer.  
Agreements with consultants, suppliers, partners 
or other middle-men must never be used to channel 
payment or other remuneration to anyone within or 
outside FSN Capital. 
10. Fair Competition 
FSN Capital will compete in a fair and ethically justi-
fiable manner within the framework of the antitrust 
and competition rules in the markets in which the 
Firm operates. ​Anti-competitive activities undermine 
confidence and trust from society, our customers, 
suppliers and other third parties.​ 
11. Correct information  
FSN Capital requires that all employees are truthful in 
their dealings with one another, our clients and other 
business partners. In our interaction with investors, 
each other, intermediaries and potential sellers of 
portfolio companies, FSN Capital will always be 
honest and fair in terms of how we act in processes 
and “only promise what we can deliver”.  
We will never take short-cuts in terms of due 
diligence of potential portfolio companies. We 
will view each deal in isolation and only base our 
investment recommendations on the merits of that 
particular transaction. 
5. Directorship, employment and other 
assignments  
Board members, Executive Advisors and employees 
are expected to show loyalty towards FSN Capital and 
the FSN Capital Funds and shall not participate in any 
competing business.   
No one must engage in other directorships, 
employment or assignments of any material signifi-
cance outside FSN Capital unless otherwise agreed 
with FSN Capital. Should a conflict of interest arise, or 
if the relevant person’s ability to perform their duties 
or fulfil their obligations to FSN Capital is compro-
mised, such approval will be evaluated and could be 
withdrawn.  
6. Personal Investments 
No FSN Capital Partners employee will participate 
for its own account in any investment opportunity in 
listed single name securities with their primary listing 
in the Nordics or DACH or unlisted securities with 
incorporation and principal activities in the Nordics or 
DACH, unless:  
i.	
such investment is made through a delegated 
discretionary portfolio investment mandate, or 
into EFTs or mutual funds; or 
ii.	 such investment is in a private company outside 
FSN Funds’ target universe with written prior 
approval from both sponsor and FSN Capital 
Partners’ compliance officer.  
All FSN Capital Partners employees are required 
to report their investments to the FSNC compliance 
officer on a semi-annual basis.    
7. Confidentiality  
Everyone at FSN Capital shall maintain all proprietary 
and confidential information in strict confidence, 
except when disclosure is authorised by FSN Capital 
Partners’ Managing Partner or required by law.  
Proprietary and confidential information 
generated and gathered in the Firm’s business is a 
valuable FSN Capital asset. Protecting this infor-
mation is critical to FSN Capital’s reputation for 
integrity and its relationship with the FSN Capital 
Funds, and ensures compliance with the complex 
regulations governing the financial services industry. 
"Proprietary information" includes all non-public 
information that might be useful to competitors 
or that could be harmful to FSN Capital, the FSN 
Capital funds, its investors, portfolio companies 
or other connections if disclosed. It includes, for 
example, intellectual property, business plans, 
personal employee information, unpublished financial 
information and identification of target portfolio 
companies. "Confidential information" is information 
that is not generally known to the public about FSN 
Capital, the FSN Capital Funds, or other parties with 
whom FSN Capital or the FSN Capital Funds have a 
business relationship and that have an expectation of, 
or legal right to, confidentiality. 
8. Insider information  
All Executive Advisors, FSN Capital board members 
and employees shall comply with applicable laws and 
regulations regarding insider information. Everyone 
is advised to take necessary measures to ensure that 
insider information regarding a potential target 
portfolio company is not received. FSN Capital should 
under no circumstance advise the FSN Capital Funds 
to act (purchase or sell shares) as a result of insider 
information.

CHAPTER 5 — Appendix
FSN Capital ESG Report 2022
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133
ACKNOWLEDGEMENT
I understand that it is my responsibility to read, to 
understand and to keep up to date with the contents 
of the Code of conduct and to seek clarification or 
further information, if needed, and to comply with the 
contents of the Code of conduct. 
I acknowledge that I have received a copy of the 
Code of Conduct for my review. I also understand that 
breach or violation of the Code of conduct may result 
in disciplinary action (which may include termination 
of employment).
I further acknowledge that I have been afforded 
the opportunity to ask any questions I have concerning 
the content of the Code of conduct.
Signature
Date
​
Name
​APPENDIX A THE TEN PRINCIPLES OF 
THE UN GLOBAL COMPACT​ 
​Human Rights​ 
	·
​Principle 1: Businesses should support and respect 
the protection of internationally proclaimed 
human rights; and​ 
	·
​Principle 2: make sure that they are not complicit 
in human rights abuses. ​​ 
Labour​ 
	·
​Principle 3: Businesses should uphold the freedom 
of association and the effective recognition of the 
right to collective bargaining;​ 
	·
​Principle 4: the elimination of all forms of forced 
and compulsory labour;​ 
	·
​Principle 5: the effective abolition of child labour; 
and​ 
	·
​Principle 6: the elimination of discrimination in 
respect of employment and occupation. ​ 
Environment​ 
	·
​Principle 7: Businesses should support a precau-
tionary approach to environmental challenges;​ 
	·
​Principle 8: undertake initiatives to promote 
greater environmental responsibility; and​ 
	·
​Principle 9: encourage the development and 
diffusion of environmentally friendly technologies. ​ 
Anti-Corruption​ 
	·
​Principle 10: Businesses should work against 
corruption in all its forms, including extortion and 
bribery.​ 
FSN Capital’s business information will be 
communicated accurately and fully, both internally 
and externally. All accounting information must be 
correctly registered and reproduced in accordance 
with laws and regulations, including relevant 
accounting standards. Any intentional act that results 
in material misstatements in financial statements will 
be treated as fraud. 
12. Social Media 
Social media can work as a rewarding platform to 
share your opinions and moments of your life. But 
social media also brings with it certain risks and 
responsibilities. Employees are ​personally​ 	
​
responsible for their content posted in social media. 
Any representative of FSNC shall refrain from sharing 
content that may compromise FSN Capital’s values 
or reputation. Keep in mind to always act in the best 
interest of FSN Capital and FSN fund investors.  
Everyone at FSN Capital shall strive to demon-
strate appropriate and respectful social media 
conduct. Be mindful that even when you make a 
statement or share content in a personal capacity, your 
content may reflect on FSN Capital. No represent-
ative of FSN Capital shall publish content, whether 
published in a private or professional capacity, that 
may reflect negatively on the professionalism or 
reputation of FSN Capital or FSN fund investors, such 
as malicious, hostile or intimidating content or content 
that might constitute discrimination or harassment.  
Be particularly careful in respect of entries 
relating to FSN Capital, FSN fund investors and 
portfolio companies. Use a professional tone of voice 
when referring to FSN Capital and make sure you are 
fair, honest and courteous in any content reflecting 
on FSN Capital and FSN fund investors and portfolio 
companies.   
Confidential information shall never be 
published and neither colleagues, customers, 
partners nor suppliers may be quoted or referenced 
without their prior consent. Everyone at FSN 
Capital must respect intellectual property rights and 
copyright-protected material.   
When in doubt, reach out to your Sponsor or FSNC 
Compliance Officer.​ 
​13. Continuous improvement​ 
​FSN Capital continually focuses on improvement. Our 
Code is subject to annual review in order to ensure 
latest best practices and requirements are accurately 
reflected and addressed. ​ 
​REPORTING AND RAISING CONCERNS​ 
​Any personnel who observes a possible violation of 
the Code, other underlying policies, and/or applicable 
laws and regulations shall report their concern 
without undue delay in accordance with FSN Capital’s 
Whistleblower Policy. ​ 
​Individuals who fail to comply with the Code, 
including those who fail to report Code violations, 
may face disciplinary action up to and including 
termination.​

CHAPTER 5 — Appendix
FSN Capital ESG Report 2022
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135
FSN Capital – Annual ESG Report – Information Page 
Please note that this ESG Report is not a marketing 
document and is provided for information purposes 
only. For the purpose of Regulation (EU) 2019/2088, 
any environmental and/or social characteristics 
of the Funds advised by FSN Capital Partners are 
those stated in the relevant Fund documentation 
and/or regulatory disclosures made pursuant to 
Regulation (EU) 2019/2088. Any ESG claims, targets, 
commitments, incentives, initiatives or outcomes are 
otherwise not binding on investment decisions and/
or management of investments made by or on behalf 
of the FSN Funds or FSN Capital Partners. Investors 
should refer to those materials for further information 
on binding ESG, goals, targets, commitments, incen-
tives, initiatives or outcomes and how they are incor-
porated into investment strategies, screening decision 
making, stewardship and engagement.
Calculation methodologies and data collection 
practices used in respect of climate change-related 
risks and the reporting thereof as a whole are 
evolving, and other asset managers are implementing 
different frameworks, methodologies, and tracking 
tools. The selection of such different but acceptable 
measurement techniques can result in materially 
different measurements. Further, these techniques are 
subject to measurement uncertainties resulting from 
inherent limitations in the nature and methods used 
to determine such data. The precision of different 
measurement techniques may also vary.
Any information provided in respect of ESG 
or climate performance of portfolio companies is 
intended to be illustrative only should not be seen as 
an indication of current or future performance. 
The SDGs are aspirational in nature. The analysis 
involved in determining whether and how certain 
investments may contribute to or support the SDGs is 
inherently subjective and dependent on a number of 
factors and the FSN Funds make no commitment or 
guarantee that they are investing in companies that 
have a formal commitment or plan or take specific 
actions to support or contribute to the SDGs. There 
can be no assurance that reasonable parties will 
agree on a decision as to whether certain investments 
contribute to or support a particular SDG.

We hope you appreciate reading this year’s ESG report. 
Please provide any feedback, comments or questions 
you may have to esg@fsncapital.com