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Nysnø Climate Investments

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

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01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

Nysnø's mission is related to greenhouse gas emissions, but we take all aspects of sustainability seriously. We integrate environmental, social and governmental issues (ESG) in all our analyses, and expect that the companies we invest in, as well as the companies that we co-invest with, have an awareness and attitude toward ESG that they put into action.

Investment principles

Nysnø's investment mandate is to invest in companies and funds that contribute, directly or indirectly, to reducing greenhouse gas emissions. The main focus for investments is the phase from technology development to commercialisation. All investments must have business in or out from Norway.

Investment strategy

Nysnø's investment strategy is to make investments in companies where Norway can provide a competitive edge, either to companies arising in Norway or foreign companies looking to establish a footprint in Norway. Our focus at point of investment is the venture stage of company development. We are sector agnostic, seeking greenhouse gas reductions across industries and business models.

When investing in funds we seek either to gain an exposure that cannot be gained through direct investments, that can be gained more efficiently through funds or that demands sector or technology specific expertise.

ESG strategy

Nysnø’s ESG approach is based on the company’s core goals:

Profitability: Nysnø' portfolio shall generate attractive risk-adjusted return on investment.
Greenhouse gas emissions: Nysnø's investments support the development and commercialisation of technologies that reduce greenhouse gas emissions. This is the company's mission.
Value Adding: Nysnø functions as a catalyst for private investment and business activities, facilitates development of technology and increases awareness of climate gas emissions and sustainability issues.
Long-term view: Nysnø has patient capital with a long-term horizon, and economic, environmental and social profitability is measured on a long-term basis. Future businesses must embrace sustainability.

Nysnø's investment criteria and ESG policy are detailed here:

01.6. Additional information [Optional].


SG 01 CC. Climate risk

01.6 CC. Indicate whether your organisation has identified transition and physical climate-related risks and opportunities and factored this into the investment strategies and products, within the organisation’s investment time horizon.

Describe the identified transition and physical climate-related risks and opportunities and how they have been factored into the investment strategies/products.

Nysnø's investment mandate is to invest in companies and funds that contribute, directly or indirectly, to reducing greenhouse gas emissions. This means that transitional risk is the opposite for our portfolio than for traditional portfolios, meaning that our portfolio will generally benefit from a rapid transition to a zero emission society. The main trans

itional risks identified relate to the phasing in and out of regulatory measures and incentives for low/zero carbon and related businesses. 

Nysnø's portfolio companies are as exposed to physical cliamte risk as companies in general in the same locations. The main identified risks are related to increased periods of heat and higher maximum temperatures, for example reliance on cloud based digital services and underlying datacentres located in areas with rapid warming and ability to conduct outdoor construction in high temperatures.

01.7 CC. Indicate whether the organisation has assessed the likelihood and impact of these climate risks?

Describe the associated timescales linked to these risks and opportunities.

Nysnø's mandate is set to prioritise low and zero emission solutions. The investment horizon is long-term. Nysnø may invest in transitional technologies, however the main focus is on companies and technologies that will be viable in a carbon neutral society. In addition to general physical climate related risk, the main risk for the portfolio is failure to act on climate change which will delay the deployment and commercialisation of the portfolio companies' business. 

01.8 CC. Indicate whether the organisation publicly supports the TCFD?

01.9 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.


Climate related business risks are integrated into the company's internal control procedure. Climate related investment risks and opportunities are integrated in the investment strategy. The company performs an annual climate risk evaluation at portfolio and company level which is considered by the Board of Directors and made available to the company's auditor. 

1.10 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.

SG 02. Publicly available RI policy or guidance documents


02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.






02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.









02.3. Additional information [Optional].

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Nysnø's Ethical Guidelines regulate conflicts of interest, employees' personal transactions, anticorruption and whistle blowing. These guidelines supplement the background law in these areas and provide guidance for employees when dealing with potential conflicts of interests. Investment decisions are made through a three step process, first through a formal vetting process in the investment team, including the CIO, then approved by the investment committee, then by final Board approval. In all instances any personal involvement or interest will disqualify the relevant committee or Board member. Further, employee engagements outside Nysnø shall be approved by the CEO, the CEO's engagements to be approved by the Board chairperson. Employees are prohibited from investing in comapnies covered by Nysnø's investment mandate. These measures reduce the potential for conflict of interest in the investmnet process and ensure that priority is given to Nysnø if a conflict of interest should arise.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

Nysnø appoints board members to the portfolio companies and has access to the companies' incident reporting. In addition Nysnø receives regular reports and is in dialogue with the comapnies regarding their business. Nysnø also maintains an internal incident register with direct reporting to Nysnø's Board in case of significant incidents.