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Pareto Asset Management AS

PRI reporting framework 2019

Asset class implementation gateway indicators [OO 10 - 12] Peering questions [OO LE 01 - HF 01]

Investment policy [SG 01 - 04] Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Outsourcing to fiduciary managers and investment consultants [SG 12] ESG issues in asset allocation [SG 13 - 15] Asset class implementation not reported in other modules [SG 16 - 17] Innovation [SG 18] Communication [SG 19]

Direct - Listed Equity Incorporation

ESG incorporation in actively managed listed equities [LEI 01 - 10] Implementation processes [LEI 01 - 10] (A) Implementation: Screening [LEI 04 - 06] (C) Implementation: Integration of ESG factors [LEI 08 - 10] Outputs and outcomes [LEI 12 - 13]

Direct - Listed Equity Active Ownership

Overview [LEA 01] Engagement [LEA 02 - 08] Outputs and outcomes [LEA 09 - 11] (Proxy) voting and shareholder resolutions [LEA 12 - 21]

Direct - Fixed Income

ESG incorporation in actively managed fixed income [FI 01 - 12] Implementation processes [FI 01 - 03] (A) Implementation: Screening [FI 04 - 06] (C) Implementation: Integration [FI 10 - 12] Fixed income - Engagement [FI 14 - 16] Outputs and outcomes [FI 17 - 18]

Confidence building measures

Confidence building measures [CM1 01 - 07]

Export Public Responses

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Basic information

OO 01. Signatory category and services

01.1. Select the services and funds you offer

Select the services and funds you offer	% of asset under management (AUM) in ranges
Fund management	0% <10% 10-50% >50%
Fund of funds, manager of managers, sub-advised products	0% <10% 10-50% >50%
Other	0% <10% 10-50% >50%	Please specify Discretionary management of securities for individual investors.
Total 100%

Further options (may be selected in addition to the above)

Hedge funds

Fund of hedge funds

01.2. Additional information. [Optional]

Pareto Asset Management AS manages UCITS, alternative investment funds and discretionary mandates.

OO 02. Headquarters and operational countries

02.1. Select the location of your organisation’s headquarters.

Norway

02.2. Indicate the number of countries in which you have offices (including your headquarters).

2-5

6-10

>10

02.3. Indicate the approximate number of staff in your organisation in full-time equivalents (FTE).

56 FTE

02.4. Additional information. [Optional]

Pareto Asset Management AS is headquartered in Oslo, Norway. Pareto Asset Management AS also has a branch in Stockholm, Sweden, and a branch office in Frankfurt, Germany.

OO 03. Subsidiaries that are separate PRI signatories

03.1. Indicate whether you have subsidiaries within your organisation that are also PRI signatories in their own right.

Yes

03.3. Additional information. [Optional]

As at 31 December 2018, Pareto Asset Management AS did not have any subsidiaries. On 1 January 2019, we acquired the Swedish company Enter Fonder AB. We do not report on a consolidated basis.

OO 04. Reporting year and AUM

04.1. Indicate the year end date for your reporting year.

31/12/2018

04.2. Indicate your total AUM at the end of your reporting year.

Include the AUM of subsidiaries, but exclude advisory/execution only assets, and exclude the assets of your PRI signatory subsidiaries that you have chosen not to report on in OO 03.2

Total AUM
Total AUM	trillions	billions	millions	thousands	hundreds
Currency
Assets in USD
Assets in USD	trillions	billions	millions	thousands	hundreds

Not applicable as we are in the fund-raising process

04.4. Indicate the total assets at the end of your reporting year subject to an execution and/or advisory approach.

Not applicable as we do not have any assets under execution and/or advisory approach

04.5. Additional information. [Optional]

OO 06. How would you like to disclose your asset class mix

06.1. Select how you would like to disclose your asset class mix.

as percentage breakdown

as broad ranges

	Internally managed (%)	Externally managed (%)
Listed equity	>50% 54	0 0
Fixed income	10-50% 35	0 0
Private equity	0 0	0 0
Property	0 0	0 0
Infrastructure	0 0	0 0
Commodities	0 0	0 0
Hedge funds	10-50% 11	0 0
Fund of hedge funds	0 0	0 0
Forestry	0 0	0 0
Farmland	0 0	0 0
Inclusive finance	0 0	0 0
Cash	0 0	0 0
Money market instruments	0 0	0 0
Other (1), specify	0 0	0 0
Other (2), specify	0 0	0 0

06.2. Publish asset class mix as per attached image [Optional].

06.3. Indicate whether your organisation has any off-balance sheet assets [Optional].

Yes

06.5. Indicate whether your organisation uses fiduciary managers.

Yes, we use a fiduciary manager and our response to OO 5.1 is reflective of their management of our assets.

No, we do not use fiduciary managers.

06.6. Provide contextual information on your AUM asset class split. [Optional]

OO 07. Fixed income AUM breakdown (Private)

OO 08. Segregated mandates or pooled funds (Not Applicable)

OO 09. Breakdown of AUM by market

09.1. Indicate the breakdown of your organisation’s AUM by market.

95 Developed Markets

5 Emerging Markets

0 Frontier Markets

0 Other Markets

Total 100% 100%

09.2. Additional information. [Optional]

Although all stock exchanges and regulated markets worldwide are of potential interest, the majority of the investments of our funds and discretionary mandates will - typically for corporate governance reasons - be domiciled/listed in developed markets.

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