UN Global Compact 2023 Communication on Progress

COMMUNICATION ON PROGRESS QUESTIONNAIRE

Governance
Policies and Responsibilities
What is the time period covered by your Communication on Progress? (MM/YYYY) – (MM/YYYY)
01 Jan 2022 - 31 Dec 2022
G1. Does the board/highest governance body or most senior executive of the company:
Linked to: GRI Disclosures 2-12, 2-14, 2-22 (2021)
(Multiple choice -Select all that apply)
Issue an annual statement about the relevance of sustainable development to the company
Issue an annual statement that addresses impacts on both people and the environment
Issue an annual statement highlighting a zero tolerance for corruption
Sign off on organizational sustainability targets
Supervise Environmental, Social, and Governance reporting
Regularly review potential risks related to the business model
None of the above
Please provide additional explanation:
For more detailed information see the relevant sections in our Integrated Report 2022: https://ir.swedfund.se/ceo https://ir.swedfund.se Ethical Compass - pp. 64-65 and Corporate Governance Report - pp. 128-132. Swedfund is committed to counteract corruption, which is stated in our Anti-Corruption Policy that is reviewed annually: https://www.swedfund.se/media/2567/swedfund_anti-corruption_policy.pdf. Results from our anti-corruption work is being reporting annually in our Integrated Report.
G2. Does the company have a publicly stated commitment regarding the following sustainability topics?
Linked to: GRI Disclosure 2-23 (2021)
(Matrix – Select one answer option per line)
No, this is not a current priority
No, but we plan to within the next two years
Yes, and the commitment is focused on our own operations
Yes, and the commitment includes our own operations and suppliers
Yes, and the commitment includes our own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Human Rights
Labour Rights/ Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
For more detailed information see our Integrated Report 2022 https://ir.swedfund.se Ethical Compass - pp. 64-65. And further, our Policy for Sustainable Development: https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf as well as our Anti-Corruption Policy: https://www.swedfund.se/media/2567/swedfund_anti-corruption_policy.pdf For Swedfund, the material part of the value chain are our portfolio companies.

G3. Does the company have in place a code of conduct regarding each of the following sustainability topics?
Linked to: NASDAQ G6.1; GRI Disclosure 2-23 (2021)
(Matrix – Select one answer option per line)

No, this is not a current priority
No, but we plan to within the next two years
Yes, focused on employee conduct
Yes, focused on employees and suppliers
Yes, focused on our own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Human Rights
Labour Rights/ Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
For more detailed information see our Integrated Report 2022 https://ir.swedfund.se Ethical Compass - pp. 64-65. And further, our Policy for Sustainable Development: https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf as well as our Anti-Corruption Policy: https://www.swedfund.se/media/2567/swedfund_anti-corruption_policy.pdf For Swedfund, the material part of the value chain are our portfolio companies.
G4. Has the company appointed an individual or group responsible for each of the following sustainability topics?
Linked to: GRI Disclosure 2-13 (2021)
(Matrix – Select one answer option per line)
No one is specifically responsible for this topic
Yes, with limited influence on outcomes (e.g., limited access to internal information, limited decision-making authority)
Yes, with moderate influence on outcomes (e.g., has access to relevant information, reports to senior manager)
Yes, with direct influence of some outcomes (e.g., has access to relevant information, includes one or more senior manager with decision making rights)
Yes, with direct influence at the highest levels of the organization (e.g., has access to relevant information, includes most senior members of organization)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
For more detailed information see our Integrated Report 2022 https://ir.swedfund.se Corporate Governance Report - pp. 128-132.
G5. Does the company have a formal structure(s) (such as a cross-functional committee) to address each of the following sustainability topics?
Linked to: GRI Disclosures 2-9, 2-13 (2021)
(Matrix – Select one answer option per line)
No formal structure
Yes, and with limited influence on outcomes (e.g., limited access to internal information necessary to understand risks, poor representation from relevant departments or functions)
Yes, with moderate influence on outcomes (e.g., it includes representatives of some functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, reports to senior manager)
Yes, with direct influence on some outcomes (e.g., it includes representatives of functions, departments, or business units most relevant for addressing the risks concerned, has access to relevant information, it involves one or more members of senior management)
Yes, and with direct influence at the highest level of the organization (e.g., full access to relevant information, it involves members at highest level of organization)
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
For more detailed information see our Integrated Report 2022 https://ir.swedfund.se Corporate Governance Report - pp. 128-132.
Prevention
G6. Does the company have a process or processes to assess risk?
Linked to: GRI Disclosure 205-1 (2016)
(Matrix – Select one answer option per line)
No, this is not a current priority
No, but we plan to within the next two years
Yes, related to our own operations
Yes, related to our own operations and suppliers [Prompts G6.1]
Yes, related to our own operations and the value chain (including suppliers, consumers, communities, other business relationships) [Prompts G6.1]
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
For more detailed information see our Integrated Report 2022 https://ir.swedfund.se Risk - pp. 42-45 and Corporate Governance Report 131-132.
G6.1 During the assessment of risk, has your company reviewed those suppliers and/or other business relationships where the risk related to human rights, labour, environment and/or anti-corruption may be particularly severe?
(Matrix – Select one answer option per line)
No
Yes
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
All portfolio companies are assessed and monitored on human rights, labour, environmental and corruption risks as a part of the investment process. For more detailed information see our Integrated Report 2022 https://ir.swedfund.se Risk - pp. 42-45 and Corporate Governance Report 131-132.
G7. Does the company have a due diligence process through which it identifies, prevents, mitigates, and accounts for actual and potential negative impacts on sustainability topics?
Linked to: GRI Disclosures 2-12, 2-23-a-ii, 3-1, 3-3-d (2021)
(Matrix – Select one answer option per line)
No, this is not a current priority
No, but we plan to within the next two years
Yes, related to our own operations
Yes, related to our own operations and suppliers [Prompts G7.1]
Yes, related to our own operations and the value chain (including suppliers, consumers, communities, other business relationships) [Prompts G7.1]
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
All portfolio companies are assessed and monitored on human rights, labour, environmental and corruption risks as a part of the investment process. For more detailed information see our Integrated Report 2022 https://ir.swedfund.se Risk - pp. 42-45, Investment process pp. 48-51 and Corporate Governance Report 131-132.
G7.1 During the due diligence process, has your company reviewed those suppliers and/or other business relationships where the risk of adverse impacts on human rights, labour, environment and/or anti-corruption may be particularly severe?
Linked to: GRI Disclosures 2-23-e, 3-1 (2021)
(Matrix – Select one answer option per line)
No
Yes
Human rights risks
Labour rights risks
Environmental risks
Corruption risks
Please provide additional explanation:
All portfolio companies are assessed and monitored on human rights, labour, environmental and corruption risks as a part of the investment process. For more detailed information see our Integrated Report 2022 https://ir.swedfund.se Risk - pp. 42-45, Investment process pp. 48-51 and Corporate Governance Report 131-132.
Concerns and Grievance Mechanisms
G8. Are there any processes through which members of the company’s workforce can raise concerns about the company’s conduct related to human rights, labour rights, environment, or anti-corruption?
Linked to: Reporting Guidance on the 10th Principle Against Anti-corruption – B3; GRI Disclosure 2-26 (2021)
(Radial – Select One)
No, this is not a current priority
No, but we plan to within two years
Yes, we have an informal process (e.g., through supervisors, others) [Prompts G8.1]
Yes, we have a formal process [Prompts G8.1]
Please provide additional explanation:
For further information see information on Swedfund's Grievance Mechanism and Whistleblowing Service: https://www.swedfund.se/media/2378/swedfund-grievance-mechanism-guidelines.pdf https://www.swedfund.se/media/2076/swedfund-whistleblowing-service-guidelinespdf.pdf
G8.1. Please provide additional detail regarding the process(es) the company has through which members of the company’s workforce can raise concerns about the company’s conduct.
Linked to: GRI Disclosure 2-26 (2021)
(Matrix – Select one answer option per line)
No
Yes
Is the process communicated to all employees/workers in local languages
Is the process available to non-employees (e.g., suppliers, consumers, communities, and other business relationships)
Is the process confidential (e.g., whistleblowing process)
Are there processes in place to avoid retaliation
Can concerns be raised about suppliers or other business relationships (e.g., clients, partners, etc.)
Other
Please provide additional explanation:
For further information see information on Swedfund's Grievance Mechanism and Whistleblowing Service: https://www.swedfund.se/media/2378/swedfund-grievance-mechanism-guidelines.pdf https://www.swedfund.se/media/2076/swedfund-whistleblowing-service-guidelinespdf.pdf
Lessons
G9. How does the company capture lessons regarding each of the following sustainability topics?
Linked to: GRI Disclosure 3-3-e (2021)
(Matrix – Select one answer option per line)
No lessons are regularly captured
Conducts root cause analyses/investigation of incidents
Conducts root cause analyses/investigation and changes organizational policies, processes, and practices accordingly
Systematically conducts root cause analyses/investigation and leverages learnings to influence both internal and external affairs
Human Rights
Labor Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
When a due diligence of a new investment has been completed, the investment team generally concludes lessons learned to inform coming due diligences and investments. When an investment is exited, an exit report including assessment of human rights, labour rights, environment and anti-corruption is conducted, as applicable. The exit report includes lessons learned. The exit report is shared with the Investment Committee, and workshops on exits are being conducted with the personnel and the Board is being informed. Further, lessons learned as a result of the regulars assessments are then integrated back into Swedfund's policies and Impact and Sustainability Management System.
Executive Pay
G10. Is executive pay linked to performance on one or more of the following sustainability topics?
Linked to: CDP W6.4 (2022), CDP F4.3a (2022), CDP C1.3a (2022); Nasdaq G3 2335; GRI Disclosure 2-19 (2021)
(Matrix – Select one answer option per line)
No, and we have no intention to change for this is not a current priority
No, but we plan to within two years
Yes
Human Rights
Labour Rights/Decent Work
Environment
Anti-Corruption
Please provide additional explanation:
For remuneration of senior executives Swedfund applies the Government’s guidelines for persons in managerial positions (see the “Guidelines for the remuneration of senior executives at Swedfund International AB”, which can be found on Swedfund’s website). Swedfund does not provide incentives or bonuses to executives. Swedfund's strategy and strategic targets include targets regarding all three pillars: Impact on society, Sustainability and Financial viability covering Human Rights, Labour Rights, Environment and Anti-Corruption. Strategy and strategic targets are basis for the annual business plans that in turn form a basis for executives' annual targets and evaluations.
Board Composition
G11. Percentage of individuals within the company’s board/highest governance body by:
Linked to: ISAR D.1.2 (2019), ISAR D.1.3 (2019); GRI Disclosures 2-9 (2021), 405-1 (2016)
(Matrix – Percentage & Radial)
Number (Please input answer as a whole number (e.g., 95% = 95))
Not applicable
Total number of board members (#)
Male (%) Note: Please input answer as whole number (e.g., 95% = 95)
Female (%) Note: Please input answer as whole number (e.g., 95% = 95)
Non-binary (%) Note: Please input answer as whole number (e.g., 95% = 95)
Under 30 years old (%) Note: Please input answer as whole number (e.g., 95% = 95)
30-50 years old (%) Note: Please input answer as whole number (e.g., 95% = 95)
Above 50 years old (%) Note: Please input answer as whole number (e.g., 95% = 95)
From minority or vulnerable groups (%) Note: Please input answer as whole number (e.g., 95% = 95)
Executive (%) Note: Please input answer as whole number (e.g., 95% = 95)
Independent (%) Note: Please input answer as whole number (e.g., 95% = 95)
Please provide additional explanation:
For further information see our Integrated Report 2022 https://ir.swedfund.se Corporate Governance Report - pp. 128-136. Information on minority or vulnerable groups is not collected. No member of the executive team is a member of the Board of Directors. Additionally, in accordance with the State's Ownership Policy, Swedfund does not report whether or not board members are independent of the owner.
G12. Do you produce sustainability reporting according to:
Linked to: Nasdaq G9.1
(Select all that apply)
National/local regulation on sustainability
Security exchange regulations
Non-Financial Reporting Directive of the European Union (NFRD)
Global Reporting Initiative (GRI)
Sustainability Accounting Standards Board (SASB, now consolidated into the IFRS Foundation)
International Integrated Reporting Council (IIRC, now consolidated into the IFRS Foundation)
Climate Disclosure Standards Board (CDSB, now consolidated into the IFRS Foundation)
Task Force on Climate-related Financial Disclosures (TCFD)
Other voluntary frameworks (Please specify in text box) [Makes text box mandatory]
No sustainability reporting according to any frameworks nor regulations outside of this Communication on Progress
Please provide additional explanation:
UNPRI - Principles for Responsible Investment
Data Assurance
G13. Is the information disclosed in this questionnaire assured by a third-party?
Linked to: CDP C10.1 (2022); GRI Disclosure 2-5 (2021)
(Select all that apply)
Limited assurance for minority of metrics (e.g., GHG emissions only)
Limited assurance for majority of metrics
Reasonable assurance for minority of metrics
Reasonable assurance for majority of metrics
Other (Please provide additional information) [Makes text box mandatory]
No assurance for any metrics
Please provide additional explanation:
Information in Swedfund's Integrated Report 2022, which forms a basis for Global Compact Report 2022, has been a subject of third party audit and/or assurance. Metrics aligned to GRI Standards in Integrated Report 2022 have been assured by third-party limited assurance. Further information, see pp. 137-138 and 150-151 of the Integrated Report 2022: https://ir.swedfund.se
Human Rights
Materiality (including Saliency)
HR1. Which of the following has the company identified as material human rights topics connected with its operations and/or value chain, whether based on their salience (e.g., the most severe potential negative impacts on people) or another basis?
Linked to: GRI Disclosure 3-2 (2021)
(Select all that apply)
Freedom of association and the effective recognition of the right to collective bargaining
Child labour
Forced labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours) [Prompts additional line ‘Working conditions (wages, working hours)’ in Questions L1, L2, L3, L4, L5, L11]
Freedom of expression [Prompts additional line ‘Freedom of expression’ in Questions HR2–HR7]
Access to water and sanitation [Prompts additional line ‘Access to water and sanitation’ in Questions HR2–HR7]
Digital security/privacy [Prompts additional line ‘Digital security/privacy’ in Questions HR2–HR7]
Gender equality and women’s rights [Prompts additional line ‘Gender equality and women's rights’ in Questions HR2–HR7]
Rights of indigenous peoples [Prompts additional line ‘Rights of indigenous peoples’ in Questions HR2–HR7]
Rights of refugees and migrants [Prompts additional line ‘Rights of refugees and migrants’ in Questions HR2–HR7]
Other [Textbox Mandatory]
No human rights topics have been identified as material
Please provide additional explanation:
In line with Swedfund's Owner Instruction's mission objectives relating to the social sustainability of investments, decent work as well as gender equality and women's economic empowerment are material topics to all Swedfund's investments. As also required in the State Ownership Policy, Swedfund is committed to work actively to comply with the UN Guiding Principles on Business and Human Rights. Swedfund requires all portfolio companies to provide employment in line with the ILO's Declaration on Fundamental Conventions and Rights at Work (covering child labour, forced labour, freedom of association and the right to collective bargaining, non-discrimination and safe and healthy working environment) and the ILO Basic Terms and Conditions of Employment (covering wages, working hours). All companies are required to contribute to increasing gender equality and counteracting unacceptable behaviours and practices in line with the ILO C190 - Violence and Harassment Convention. Additional topics can be material at the level of individual investments.
Commitment
HR2. Does the company have a policy commitment in relation to the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosures 2-23-a-iv, 2-23-b, 3-3-c (2021)
(Matrix – Select one answer option per line)
No, and we have no plans to develop a policy
No, but we plan to within the next two years
Yes, included within a broader policy or as a stand-alone policy
Gender equality and women’s rights
Please provide additional explanation:
Swedfund recognises that all business enterprises should respect human rights including labour rights and is committed to work actively to comply with the United Nations Guiding Principles on Business and Human Rights (UNGP). Further, Swedfund is committed to promoting women’s empowerment and gender equality, which are fundamentally linked to our mission to contribute to poverty and inequality reduction. For further information, see Swedfund's Policy for Sustainable Development: https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf

Please input the year the relevant human rights policy was last reviewed
Year (YYYY)
Gender equality and women’s rights
Please provide additional explanation:
Swedfund's Policy for Sustainable Development is subject to annual review. Latest revision 2021.
HR2.1. For each human rights policy commitment, is it:
Linked to: GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Matrix – Select all that apply for each line)
Aligned with international human rights standards
Publicly available
Approved at most senior level of the company
Applied to the company’s own operations
Applied to the company’s own operations and suppliers
Applied to the company’s own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Developed involving human rights expertise from inside and outside the company
Other (Please provide additional information in the mandatory text box)
Gender equality and women’s rights
Please provide additional explanation:
Swedfund recognises that all business enterprises should respect human rights including labour rights and is committed to work actively to comply with the United Nations Guiding Principles on Business and Human Rights (UNGP). Further, Swedfund is committed to promoting women’s empowerment and gender equality, which are fundamentally linked to our mission to contribute to poverty and inequality reduction. For further information, see Swedfund's Policy for Sustainable Development: https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf
Prevention
HR3. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosures 3-1-b, 3-3-f (2021)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No engagement on this topic
To better understand the risks/impacts in question
To discuss potential ways to prevent or mitigate the risks/impacts in question
To agree on a way to prevent/mitigate the risks/impacts in question
To assess progress in preventing/ mitigating the risks/ impacts in question
To collaborate in the prevention/mitigation of the risks/impacts in question
Gender equality and women’s rights
Please provide additional explanation:
Swedfund engages with stakeholders and civil society organisations at the company level through stakeholder dialogues that can be general or address specific topics. Swedfund also expects its portfolio companies to engage with stakeholders in line with IFC Performance Standards 1 on Assessment and Management of Environmental and Social Risks and Impacts and 4 on Community Health, Safety, and Security. Further, Swedfund engages directly with the project specific stakeholders, as relevant. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se and more specifically p. 19 for activities during the reporting year.
HR4. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this human rights topic?
Matrix will be populated only for the human rights issues selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021)
(Matrix – Select all that apply for each line)
Provided internal training/ capacity building for the direct workforce
Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)
Conducted an audit process and/or corrective action plan
Collective Action with peers or other stakeholders, in particular workers’ organizations, to address the issue
Collaborated with governmental or regulatory bodies
Other (Please provide additional information in the mandatory text box)
No action within reporting period
Gender equality and women’s rights
Please provide additional explanation:
All new investment opportunities go through a thorough due diligence and active investments are being monitored. For detailed information, see Swedfund's Integrated Report 2022 Investment Process pp. 48-51. Swedfund’s overall goal in the area of gender equality and women’s economic empowerment is to ensure that, by no later than three years from the date of investment, at least 60 percent of the investments in our portfolio meet at least one of the criteria established by the G7-founded initiative 2X Challenge in 2018. The aim is to identify and promote investments that can either strengthen women’s development, women-led companies and companies that employ many women, or offer products and services that specifically improve the situation facing women or girls in society. Swedfund takes action on and offers tailored programs to address gender equality and women's economic empowerment throughout the investment life cycle. Potential investments are assessed on the 2X criteria and any gaps related to gender equality that are identified are integrated into an overall ESG Action Plan that is to be implemented within a limited time frame. Swedfund also offers its portfolio companies a wide range of trainings and programs on gender equality and women's economic empowerment via Technical Assistance funding, for example the Women4Growth program, the Gender Lens Investing training for fund managers and awareness raising on gender based violence and sexual exploitation, abuse and harassment, the latter with collaboration with a women's rights organisation Kvinna till Kvinna. For further information see Swedfund's Integrated Report 2022: https://ir.swedfund.se/ pp. 72-73.
HR5. Who receives training for the following human rights topics? Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021)
(Matrix – Select all that apply for each line)
No training provided
Select employees
All employees
Contractors
Direct suppliers of the organization
Indirect suppliers of the organization
Other – such as partners, clients, etc.
Gender equality and women’s rights
Please provide additional explanation:
Swedfund offers various training programs and workshops related to gender equality and women's economic empowerment for its portfolio companies via Technical Assistance funding in collaboration with external experts including the Women4Growth program, the Gender Lens Investing training for fund managers and awareness raising on gender based violence and sexual exploitation, abuse and harassment, the latter with collaboration with a women's rights organisation Kvinna till Kvinna. Further, during 2022 a training on gender based violence and sexual exploitation, abuse and harassment was provided for all personnel at Swedfund. For further information see Swedfund's Integrated Report 2022: https://ir.swedfund.se.
HR6. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following human rights topics? Matrix will be populated only for the human rights issues selected in HR1.
Linked to: GRI Disclosure 3-3-e (2021)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No monitoring of progress
Review topics on ad hoc basis
Set annual targets/goals, track progress over time (internal programmes only)
Set annual targets/goals, track progress over time (internal and external programmes)
Other (Please provide additional information in the mandatory text box)
Gender equality and women’s rights
Please provide additional explanation:
We work actively and continuously with our portfolio companies, including monitoring of sustainability risks and impacts, which were identified during the due diligence phase. Visits, active board work, monitoring of data via annual monitoring reports, and internal and third party audits are some of the tools for active ownership. In connection with fund investments, we can have direct contact with the underlying holdings of the funds, e.g. through visits, analyses, ESG & Impact initiatives and Technical Assistance funds. Progress against portfolio level targets, including gender equality target (60% of portfolio companies to meet at least one of the 2X criteria within 3 years from time of investment), are being monitored annually and reported in our Integrated Report. For further information see Swedfund's Integrated Report 2022: https://ir.swedfund.se.
Response and Reporting
HR7. During the reporting period, has the company been involved in providing or enabling remedy if it has caused or contributed to adverse impact associated with the following human rights topic(s)?
Matrix will be populated only for the human rights topics selected in HR1.
Linked to: GRI Disclosure 3-3-d-ii (2021)
(Matrix – Select one answer option per line)
No remedy provided/enabled
Yes, remedy provided/enabled
No adverse impact identified or caused
Choose to not disclose
Gender equality and women’s rights
Please provide additional explanation:
Swedfund is committed to safeguarding human rights, addressing any adverse human rights impacts, and working actively to comply with the United Nations Guiding Principles on Business and Human Rights (UNGP). At the same time, the markets in which Swedfund’s portfolio companies operate often lack strong institutions, robust legislation and the implementation and follow-up of laws and regulations. Portfolio companies are required to report major incidents to Swedfund. Furthermore, Swedfund has a whistleblowing system and grievance mechanism in place to be able to adequately investigate and respond to serious irregularities. Swedfund is not aware of causing or contributing to adverse Human Rights impacts subject to remedy during the reporting period. For further information see Swedfund's Integrated Report 2022: https://ir.swedfund.se.
HR8. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to take to implement the human rights principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021)
(Text Box)
Specific statement on human rights is included in Swedfund’s Policy for Sustainable Development. This Policy was revised in 2021 but retains the same focus on human rights. During 2020, a ’Guiding Note on Human Rights’ was also published describing how human rights are incorporated into Swedfund’s investment activities. This Guiding Note is subject of regular revisions, as the process of assessing and managing human rights is continuously evolving. The aim of the process for assessing human rights in investment activities is to identify, mitigate and account for potential and actual negative impacts on human rights. The ambition is to apply this process in connection with decisions concerning new investments, regularly during the value creation phase in the event of changes in circumstances, and for companies in the exit phase. Human rights are already taken into account at an early stage in the investment process by preparing an assessment of the project as regards to human rights based on country, location, operating conditions, type of business and business partners. During the screening process, i.e. stage two of the analysis phase of a potential investment, a risk analysis is carried out during which human rights risks and impacts are analysed in more detail. Swedfund then pursues a dialogue with the portfolio companies concerning the human rights. Depending on the outcome of this analysis, a decision is then made as to whether a more detailed human rights analysis should be carried out. This is carried out using internal resources or with the support of an external expert. The mitigation of identified risks and impacts is incorporated into the ESG Action Plan (ESGAP), which forms part of the investment agreement. For further information see Swedfund's Integrated Report 2022: https://ir.swedfund.se pp. 142-143.
Labour
Commitment
L1. Does the company have a policy commitment in relation to the following labour rights principles? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-c (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)

No, and we have no plans to develop a policy
No, but we plan to within the next two years
Yes, included within a broader policy or as a stand-alone policy [Prompts L1.1]
Not applicable (Please provide additional information in the mandatory text box)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
Swedfund recognises that all business enterprises should respect human rights including labour rights. All of our portfolio companies shall act consistently with the ILO’s Declaration on Fundamental Principles and Rights at Work and the ILO’s Basic Terms and Conditions of Employment covering the related labour topics. Further information, please see Swedfund's Policy for Sustainable Development: https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf

Please input the year the relevant labour rights policy was last reviewed
Year (YYYY)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
Swedfund's Policy for Sustainable Development is subject of annual review. Latest revision 2021.
L1.1. For each labour rights policy, is it:
Linked to: ILO C155 - Occupational Safety and Health Convention 1981 (No. 155); GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Matrix – Select all that apply for each line)
Aligned with international labour standards
Publicly available
Approved at most senior level of the company
Applied to the company’s own operations
Applied to the company’s own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Developed in consultation with workers and their representatives
Developed involving labour rights expertise from inside and outside the company
Other (Please provide additional information in the mandatory text box)
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
In Swedfund's Policy for Sustainable Development, which is externally available, Swedfund requires all portfolio companies to provide jobs in line with the ILO's Declaration on Fundamental Conventions and Rights at Work (covering child labour, forced labour, freedom of association and the right to collective bargaining, non-discrimination and safe and healthy working environment) and the ILO Basic Terms and Conditions of Employment (covering wages, working hours). Further, Swedfund's internal operations are guided by employee policies and processes, and a collective bargaining agreement that covers all employees at the Stockholm office in Sweden. Employees outside of Stockholm office are being provided with working conditions similar to the collective bargaining agreement. Swedfund's employee association has been consulted regularly throughout the reporting period. For more information, see Swedfund's Policy for Sustainable Development: https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf and Swedfund's Integrated Report 2022: https://ir.swedfund.se/
L1.2. Does the existing company’s policy on freedom of association and collective bargaining:
Linked to: ILO C155 - Occupational Safety and Health Convention 1981 (No. 155); GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Multiple choice – Select all that apply)
Reference the respect for the right of all workers to form and join a trade union of their choice without fear of intimidation or reprisal and protect workers against acts of antiunion discrimination
Prohibit any acts of interference in trade unions
Facilitate the collective bargaining with the trade union representatives
Provide trade union representatives with information required for meaningful bargaining in the context of bona fide negotiations
Reference the respect for the right of workers to submit grievances without suffering
We do have a policy on freedom of association and collective bargaining, but it does not include any of these details
We do not have a policy on freedom of association and collective bargaining
Please provide additional explanation:
Regardring Freedom of Association and Collective Bargaining Swedfund refers to the following ILO Conventions: The Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87); Right to Organise and Collective Bargaining Convention, 1949 (No. 98). For further information, see Swedfund's Policy for Sustainable Development: https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf
Prevention
L2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosures 3-1-b and 3-3-f (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No engagement on this topic
To better understand the risks/impacts in question
To discuss potential ways to prevent or mitigate the risks/ impacts in question
To agree on a way to prevent/mitigate the risks/impacts in question
To assess progress in preventing/ mitigating the risks/ impacts in question
To collaborate in the prevention/ mitigation of the risks/ impacts in question
Other (Please provide additional information) [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced Labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
Swedfund engages with stakeholders and civil society organisations at the company level through stakeholder dialogues that can be general or address specific topics. Swedfund also expects its portfolio companies to engage with stakeholders in line with IFC Performance Standards 1 on Assessment and Management of Environmental and Social Risks and Impacts and 4 on Community Health, Safety, and Security. Further, Swedfund engages directly with the project specific stakeholders, as relevant. Throughout the investment process, from screening until the exit stage, labour topics are considered and collaboration takes place to identify, prevent and mitigate relevant risks. This depends on the type of investment and investment stage. However, for each investment labour topics and prevention of labour risks and impacts are an integral part of the investment process. For each investment Swedfund conducts a thorough due diligence covering the ILO's Declaration on Fundamental Conventions and Rights at Work and the ILO Basic Terms and Conditions of Employment. Identified gaps and mitigating measures are included in the ESG Action Plan, which implementation is monitored in the active ownership phase. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se
L3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with this labour rights topic? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select all that apply for each line)
Provided internal training/ capacity building for the direct workforce
Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)
Conducted an audit process and/or corrective action plan
Collective Action with peers or other stakeholders, in particular workers’ organizations, to address the issue
Collaborated with governmental or regulatory bodies
Other (Please provide additional information) [Makes text box mandatory]
No action within reporting period
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
Swedfund engages with stakeholders and civil society organisations at the company level through stakeholder dialogues that can be general or address specific topics. Swedfund also expects its portfolio companies to engage with stakeholders in line with IFC Performance Standards 1 on Assessment and Management of Environmental and Social Risks and Impacts and 4 on Community Health, Safety, and Security. Further, Swedfund engages directly with the project specific stakeholders, as relevant. Throughout the investment process, from screening until the exit stage, labour topics are considered and collaboration takes place to identify, prevent and mitigate relevant risks. This depends on the type of investment and investment stage. However, for each investment labour topics and prevention of labour risks and impacts are an integral part of the investment process. For each investment Swedfund conducts a thorough due diligence covering the ILO's Declaration on Fundamental Conventions and Rights at Work and the ILO Basic Terms and Conditions of Employment. Identified gaps and mitigating measures are included in the ESG Action Plan, which implementation is monitored in the active ownership phase. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se, more specifically p. 19, 74, 76-77, 143-144
L4. Who receives training for the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select all that apply for each line)
No training provided
Select employees
All employees
Contractors
Direct suppliers of the organization
Indirect suppliers of the organization
Other – such as partners, clients, etc.
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
When a need is identified during due diligence or the active ownership phase, training can be deployed for portfolio companies through Technical Assistance funding, either as targeted projects or as a structural training program to further strengthen the portfolio companies' implementation of the relevant ILO Conventions. Furthermore, when internal training needs are identified, training for Swedfund's investment professionals, HR personnel, the executive management and the Board of Directors are being conducted.
L5. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No monitoring on progress
Review topics on ad hoc basis
Set annual targets/goals, track progress over time (internal programmes only)
Set annual targets/goals, track progress over time (internal and external programmes)
Other (Please provide additional information) [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
We work actively and continuously with our portfolio companies, including monitoring of sustainability risks and impacts, which were identified during the due diligence phase. Visits, active board work, monitoring of data via annual monitoring reports, and internal and third party audits are some of the tools for active ownership. In connection with fund investments, we can have direct contact with the underlying holdings of the funds, e.g. through visits, analyses, ESG & Impact initiatives and Technical Assistance funds. Progress against portfolio level targets, including targets related to decent work (100% of portfolio companies to act in line with the ILO Declaration on Fundamental Principles and Rights at Work and the ILO Basic Terms and Conditions of Employment within 3 years from time of investment), are being monitored annually and reported in our Integrated Report. For further information see Swedfund's Integrated Report 2022: https://ir.swedfund.se.
Performance
L6. Do(es) the existing collective bargaining agreement(s) provide(s) more favourable rights than those provided in legislation, where appropriate?
(Select all that apply)
Yes, by providing more favourable conditions related to wages
Yes, by providing more favourable conditions related to working hours
Yes, by providing more favourable conditions related to health coverage and/or sick leave
Yes, by providing additional rights not otherwise provided (Please provide additional information) [Makes text box mandatory]
There is (are) no existing collective bargaining agreement(s)
No
Please provide additional explanation:
On portfolio company level, Swedfund expects working conditions in line with the relevant ILO conventions. For Swedfund's own operations, a collective bargaining agreement covers all employees at the Stockholm (Sweden) office. Employees outside of the Stockholm office are being provided with working conditions similar to the collective bargaining agreement.
L7. In the course of the reporting period, what was the percentage of women in managerial positions? (%)
Linked to: ISAR C.1.1
(Matrix – Text Box with option for Unknown or N/A)
Percent women (Please input a whole number e.g., 50% = 50)
Unknown
Managerial position
Please provide additional explanation:
Additionally, on portfolio company level, the percentage of women in senior management positions is 28%.
L8. What was the average ratio of the basic salary and remuneration of women to men (comparing jobs of equal value) during the reporting period?
Linked to: GRI Disclosure 405-2 (2016)
(Matrix – Text Box with option for Unknown or N/A)
Salary ratio (Please input a whole number e.g., 50% = 50)
Unknown
Choose to not disclose
Women/Men(%)
Please provide additional explanation:
It is required by Swedish law to assess the gender pay gap (comparing jobs of equal value) between men and woman. The results of the assessment and mitigating measures are shared and discussed with the relevant labour unions. For 2022, no gender pay gap has been identified. Additionally, Swedfund does not yet report gender pay gap information on portfolio company level.
L9. In the course of the reporting period, how frequently were workers injured (injuries per hour worked)?
Linked to: ISAR C.3.2; GRI Disclosure 403-9 (2018)
(Matrix – Text Box with option for Unknown or N/A)
Frequency of injury (Please input a whole number e.g., 50% = 50)
Unknown
Choose to not disclose
Frequency of injury
Please provide additional explanation:
Zero injuries have been reported in Swedfund's own operations. 44 serious incidents have been reported in Swedfund's portfolio companies and portfolio companies of funds.
L10. In the course of the reporting period, what was the company’s incident rate (injuries per worker)?
Linked to: ISAR C.3.2; GRI Disclosure 403-9 (2018)
(Matrix – Text Box with option for Unknown or N/A)
Incident rate (Please input a whole number e.g., 50% = 50)
Unknown
Choose to not disclose [Makes text box mandatory]
Incident rate
Please provide additional explanation:
Zero injuries have been reported in Swedfund's operations. 40 serious incidents have been reported in Swedfund's portfolio companies and portfolio companies of funds.
Response and Reporting
L11. In the course of the reporting period, has the company been involved in providing or enabling remedy if it has caused or contributed to the adverse impact associated with the following labour rights topics? For the user, the “Working conditions (wages, working hours)” option would be visible only if selected in HR1.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Matrix – Select one answer option per line)
No remedy provided/enabled
Yes, remedy provided/enabled
No adverse impact identified or caused
Choose to not disclose [Makes text box mandatory]
Freedom of association and the effective recognition of the right to collective bargaining
Forced labour
Child labour
Non-discrimination in respect of employment and occupation
Safe and healthy working environment
Working conditions (wages, working hours)
Please provide additional explanation:
Swedfund is committed to safeguarding human rights including labour rights, addressing any adverse human rights impacts, and working actively to comply with the United Nations Guiding Principles on Business and Human Rights (UNGP) coupled with the principles set out in the ILO Declaration on Fundamental Principles and Rights at Work. At the same time, the markets in which Swedfund’s portfolio companies operate often lack strong institutions, robust legislation and the implementation and follow-up of laws and regulations. Portfolio companies are required to report major incidents to Swedfund. Furthermore, Swedfund has a whistleblowing system and grievance mechanism in place to be able to adequately investigate and respond to serious irregularities. Swedfund is not aware of causing or contributing to adverse labour rights impacts subject to remedy during the reporting period. For further information see Swedfund's Integrated Report 2022: https://ir.swedfund.se.
L12. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to take to implement the labour principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 407 (2016), GRI 409 (2016), GRI 408 (2016), GRI 406 (2016), GRI 403 (2018)
(Text Box)
A Handbook for implementing the Decent Work agenda for portfolio companies has been developed: the Good Practice Handbook on Decent Work. This offers practical guidance regarding compliance with international standards, as well as tools for improving the quality of working conditions. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se, more specifically p. 19, 74, 76-77, 143-144.
Environment
Commitment
E1. Does the company have a policy commitment on the following environmental topics?
Linked to: CDP C4.1 (2022), CDP F6.1 (2022), CDP W6.1 (2022); GRI Disclosure 3-3-c (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020),GRI 302 (2016)
(Matrix – Select one answer option per line)
No, and we have no plans to develop a policy
No, but we plan to within the next two years
Yes, included within a broader policy or as a stand-alone policy [Prompts E1.1]
Not applicable (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
In line with Swedfund's Owner Instruction's mission objectives relating to the environmental and climatic sustainability of investments, Swedfund has specific targets on climate, which is a material topic for our portfolio. Other environmental topics can be relevant at the level of individual investments. Swedfund is committed to protecting the environment and climate. In line with Swedfund's Policy for Sustainable Development, all portfolio companies are required to develop, implement, and maintain an appropriate Environmental and Social Management Systems and adhere to relevant IFC Performance Standards, as appropriate to the size and nature of the business. Furthermore, when relevant, portfolio companies should adopt additional international environmental guidelines to manage key risks and impacts of the company, such as guidelines on water, forestry, land rights, and biodiversity. Please see Swedfund's Policy for Sustainable Development for further information https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf.
Please input the year the relevant environment policy was last reviewed
Year (YYYY)
Climate change
Please provide additional explanation:
Swedfund's Policy for Sustainable Development is subject of annual review. Latest revision 2021.
E1.1. For each environmental policy commitment, is it:
Linked to: CDP C4.1 (2022), CDP F6.1 (2022), CDP W6.1 2022; GRI Disclosures 2-23-c, 2-23-d, 2-23-e (2021)
(Matrix – Select all that apply for each line)
Aligned with international environmental standards
Publicly available
Approved at most senior level of the company
Applied to the company’s own operations
Applied to the company’s own operations and the value chain (including suppliers, consumers, communities, other business relationships)
Developed involving environmental expertise from inside and outside the company
Other (Please provide additional information in the mandatory text box)
Climate change
Please provide additional explanation:
Please see Swedfund's Policy for Sustainable Development for further information https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf. For additional information, please see Swedfund's Guiding Note on Climate: https://www.swedfund.se/media/2493/swedfund-guiding-note-climate.pdf.
Prevention
E2. In the course of the reporting period, has the company engaged with affected stakeholders or their legitimate representatives in relation to the following environmental topics?
Linked to: GRI Disclosures 3-1-b and 3-3-f (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select one answer option per line)

Please select the company’s highest level of engagement. Options progress from left to right.
No engagement on this topic
To better understand the risks/impacts in question
To discuss potential ways to prevent or mitigate the risks/ impacts in question
To agree on a way to prevent/mitigate the risks/impacts in question
To assess progress in preventing/ mitigating the risks/ impacts in question
To collaborate in the prevention/ mitigation of the risks/ impacts in question
Other (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Swedfund engages with stakeholders and civil society organisations at the company level through stakeholder dialogues that can be general or address specific topics. Swedfund also expects its portfolio companies to engage with stakeholders in line with IFC Performance Standards 1 on Assessment and Management of Environmental and Social Risks and Impacts and 4 on Community Health, Safety, and Security. Further, Swedfund engages directly with the project specific stakeholders, as relevant. Throughout the investment process, from screening until the exit stage, environmental topics are considered and collaboration takes place to identify, prevent and mitigate relevant risks. This depends on the type of investment and investment stage. However, for each investment environmental topics and prevention of environmental risks and impacts are an integral part of the investment process. For each investment Swedfund conducts a thorough due diligence covering the IFC Performance Standards and applies a climate lens to assess the climate impacts and risks of the investment. Identified gaps and mitigating measures are included in the ESG Action Plan, which implementation is monitored in the active ownership phase. Swedfund also deploys Technical Assistance funds in relation to climate change, for example climate change mitigation projects. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se
E3. What type of action has the company taken in the reporting period with the aim of preventing/mitigating the risks/impacts associated with these environmental topics?
Linked to: GRI Disclosure 3-3-d (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-iv (2016)
(Matrix – Select all that apply for each line)
Provided internal training/ capacity building for the direct workforce
Built capacity among relevant business relationships (e.g., suppliers, consumers, communities)
Conducted an audit process and/or corrective action plan
Collective Action with peers or other stakeholders, in particular workers’ organizations, to address the issue
Collaborated with governmental or regulatory bodies
Other (Please provide additional information) [Makes text box mandatory]
No action within reporting period
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Swedfund engages with stakeholders and civil society organisations at the company level through stakeholder dialogues that can be general or address specific topics. Swedfund also expects its portfolio companies to engage with stakeholders in line with IFC Performance Standards 1 on Assessment and Management of Environmental and Social Risks and Impacts and 4 on Community Health, Safety, and Security. Further, Swedfund engages directly with the project specific stakeholders, as relevant. Throughout the investment process, from screening until the exit stage, environmental topics are considered and collaboration takes place to identify, prevent and mitigate relevant risks. This depends on the type of investment and investment stage. However, for each investment environmental topics and prevention of environmental risks and impacts are an integral part of the investment process. For each investment Swedfund conducts a thorough due diligence covering the IFC Performance Standards and applies a climate lens to assess the climate impacts and risks of the investment. Identified gaps and mitigating measures are included in the ESG Action Plan, which implementation is monitored in the active ownership phase. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/ and specifically the case study on investment Serengeti Energy (p. 26) and relevant information on investment Climate Investor Two (p. 55), and actions during the reporting year on pp. 24-25.
E4. How does the company assess progress in preventing/mitigating the risks/impacts associated with the following environmental topics?
Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select one answer option per line)
Please select the company’s highest level of engagement. Options progress from left to right.
No monitoring of progress
Review topics on ad hoc basis
Set annual targets/ goals, track progress over time (internal programmes only) [Prompts E4.1 and E4.2]
Set annual targets/goals, track progress over time (internal and external programmes) [Prompts E4.1 and E4.2]
Other (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Throughout the investment process, from screening until the exit stage, environmental topics are considered and collaboration takes place to identify, prevent and mitigate relevant risks. This depends on the type of investment and investment stage. However, for each investment environmental topics and prevention of environmental risks and impacts are an integral part of the investment process. For each investment Swedfund conducts a thorough due diligence covering the IFC Performance Standards and applies a climate lens to assess the climate impacts and risks of the investment. Identified gaps and mitigating measures are included in the ESG Action Plan, which implementation is monitored in the active ownership phase. Progress against portfolio level targets, including targets related to environment and climate (climate neutral portfolio by 2045, decreasing climate emissions over time and 100% of portfolio companies to implement an environmental and social management system within 3 years from time of investment), are being monitored annually and reported in our Integrated Report. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se
E4.1. For each environmental topic for which the company sets timebound goals/targets, what kind of targets has the company set? Please give a description of targets (e.g., what is the target, absolute vs. intensity, externally verified, on track, etc.)
Linked to: CDP F6.1 (2022); GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Text Box)
1. Swedfund’s investment portfolio shall be climate neutral by 2045, which means that the GHG emissions from the portfolio should be net zero according to the IPCC's definition. 2. The portfolio’s average GHG emissions per invested SEK (Swedish Krona) shall decrease over time (i.e. the average carbon intensity of the portfolio), using 2020 as a baseline. 3. 100% of portfolio companies shall implement an Environmental and Social Management System within three years from the time of the investment. For further information and progress on these targets, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/, more specifically pp. 70-71, 78-79.
E4.2. For each environmental topic in which the company sets timebound goals/targets, how is progress against target/goal tracked?
Linked to: GRI Disclosure 3-3-e (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select all that apply for each line)
Progress is reviewed against goals annually or more frequently
Progress is reported internally to the most senior level
Progress is reported externally
Other (Please provide additional information in the mandatory text box)
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Climate related targets: 1. Swedfund’s investment portfolio shall be climate neutral by 2045, which means that the GHG emissions from the portfolio should be net zero according to the IPCC's definition. 2. The portfolio’s average GHG emissions per invested SEK (Swedish Krona) shall decrease over time (i.e. the average carbon intensity of the portfolio), using 2020 as a baseline. Environmental target - topics included in the environmental management system varies depending on the individual investment: 3. 100% of portfolio companies shall implement an Environmental and Social Management System within three years from the time of the investment. For further information and progress on these targets, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/, more specifically pp. 70-71, 78-79.
E5. In the course of the reporting period, has the company been involved in providing or enabling remedy for any impacts associated with the following environmental topic(s)?
Linked to: GRI Disclosure 3-3-d-ii (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016), and GRI Disclosure 201-2-a-iv (2016)
(Matrix – Select one answer option per line)
Yes, remedy provided/enabled
No remedy provided/enabled
No adverse impact identified or caused
Choose to not disclose
Climate change
Water
Oceans
Forests/biodiversity/land use
Air pollution
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.)
Energy & resource use
Please provide additional explanation:
Swedfund is committed to protecting the environment and climate. At the same time, the markets in which Swedfund’s portfolio companies operate often lack strong institutions, robust legislation and the implementation and follow-up of laws and regulations. Portfolio companies are required to report major incidents to Swedfund. Furthermore, Swedfund has a whistleblowing system and grievance mechanism in place to be able to adequately investigate and respond to serious irregularities. Swedfund is not aware of causing or contributing to adverse environmental impacts subject to remedy during the reporting period. For further information see Swedfund's Integrated Report 2022: https://ir.swedfund.se.
Climate Action
E6. What were the company’s gross Scope 1 and Scope 2 global greenhouse gas emissions (GHG) for the reporting period?
Linked to: CDP C6.1 (2022), CDP C6.3 (2022), CDP C6.5 (2022); GRI Disclosures 305-1, 305-2, 305-3 (2016); ISAR B.3.1; ISAR B.3.2
(Matrix – Select one answer option per line)
Measured Total Emissions (tCO2e)
We did not measure our gross GHG emissions [Please explain in the mandatory text box]
Scope 1 emissions
Scope 2 emissions
Please provide additional explanation:
Scope 1 total emissions: 0.1 tCO2e Scope 2 total emissions: 1.9 tCO2e For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/ more specifically p.143
E7. What were the company’s gross Scope 3 global greenhouse gas emissions (GHG) for the reporting period?
Linked to: CDP C6.1 (2022), CDP C6.3 (2022), CDP C6.5 (2022); GRI Disclosures 305-1, 305-2, 305-3 (2016); ISAR B.3.1; ISAR B.3.2
(Multiple choice– Select one)
We fully measured Scope 3 GHG emissions [Please input the measured tCO2e in the text box below]
We partially measured Scope 3 GHG emissions [Please input the measured tCO2e in the text box below] [Prompts E7.1]
We did not measure Scope 3 GHG emissions
Please provide additional explanation:
Business travel: 595.4 tCO2e Portfolio companies: 114 tC2e For additional information on the calculations and methodology used, please see Swedfund's Integrated Report 2022: https://ir.swedfund.se/ pp. 70-71, 143.
E7.1. Which Scope 3 categories are included in the organization’s Scope 3 emissions calculation?
Linked to: GRI Disclosure 305-3 (2016); CDP C6.5 2022
(Multiple choice – Select all that apply)
Purchased goods and services
Capital goods
Fuel- and energy-related activities
Upstream transportation and distribution
Waste generated in operations
Business travel
Employee commuting
Upstream leased assets
Downstream transportation and distribution
Processing of sold products
Use of sold products
End-of-life treatment of sold products
Downstream leased assets
Franchises
Investments
Other - upstream
Other - downstream
Unknown
Please provide additional explanation:
E8. What percentage of the company’s revenue was invested in R&D of low-carbon products/services during this reporting period?
Linked to: CDP C4.3c (2022), CDP4.2b (2022); (partially linked to) ISAR A.3.3
(Matrix – Text Box with option for Unknown or N/A)
Percent of revenue (Please input a whole number e.g., 50% = 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
R&D for low-carbon products/services
Please provide additional explanation:
For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/
E9. Has the organization acted to support climate change adaptation and resilience?
Linked to: GRI Disclosure 201-2-a-iv (2016)
(Select all that apply)
We have taken action to increase organization-wide resilience to climate change
We have taken action to increase resilience in our supply chains
We have taken action to increase resilience in the communities in which we operate
We have provided funding for climate change adaptation and resilience initiatives and projects
We have not taken actions to build climate change resilience in the reporting period
Unknown
Please provide additional explanation:
Swedfund has committed to align with the goals of the Paris Agreement, which aims to limit global warming well below 2, preferably to 1.5 degrees Celsius compared to pre-industrial levels. In line with this, Swedfund shall both i. invest in low emission pathways and climate resilient development; and ii. contribute towards net zero emissions. During the reporting period Swedfund invested in portfolio companies that contribute specifically to climate resilience and adaptation, such as Climate Investor Two. Further, Swedfund develops and funds climate related projects through Technical Assistance funding for our portfolio companies and through the Project Accelerator in developing countries. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se.
Energy/Resource Use
E10. Please report the company’s renewable energy consumption as a percentage of total energy consumption in the reporting period.
Linked to: ISAR B.5.1; GRI Disclosure 302-1 (2016)
(Matrix – Text Box with option for Unknown)
% of total energy consumption (Please input a whole number e.g., 50% = 50)
Unknown
Renewable energy consumption as % of total energy consumption:
Please provide additional explanation:
Swedfund’s head office in Stockholm has a green lease agreement based on 100 percent renewable electricity. For our office in Nairobi, there are no environmental options for the supply of electricity and heat.For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se.
Technology
E11. What percent of the company’s revenue came from low-carbon products/services during this reporting period? If applicable, please give a description of the products/services included in your calculation (e.g., relevant certifications)
Linked to: SASB CG-MR-410a.1a; WEF Common Metrics
(Matrix – Text Boxes with option for Unknown or N/A)
Percent of total revenue (%) (Please input a whole number e.g., 50% = 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Low-carbon products and services/total revenue for the reporting period
Please provide additional explanation:
For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/
Materiality-specific Questions
E12. Which of the following has the company identified as material environmental topics connected with its operations and/or value chain (e.g. the most severe actual or potential negative impacts on people and/or the environment)?
Linked to: GRI Disclosure 3-2 (2021)
(Select all that apply)
Water [Prompts questions E13 and E14]
Forests/biodiversity/land use [Prompts questions E15, E16 and E17]
Air pollution [Prompts questions E18]
Waste (e.g., chemical spills, solid waste, hazardous, plastic, etc.) [Prompts questions E19, E20, E21]
None of these topics have been identified as material by the company
Please provide additional explanation:
In line with Swedfund's Owner Instruction's mission objectives relating to the environmental and climatic sustainability of investments, Swedfund has specific targets on climate, which is a material topic for our portfolio. Other environmental topics can be relevant at the level of individual investments. Swedfund is committed to protecting the environment and climate. In line with Swedfund's Policy for Sustainable Development, all portfolio companies are required to develop, implement, and maintain an appropriate Environmental and Social Management System and adhere to relevant IFC Performance Standards, as appropriate to the size and nature of the business. Furthermore, portfolio companies should adopting additional international environmental guidelines to manage key risks and impacts of the company, such as guidelines on water, forestry, land rights, and biodiversity when relevant. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/
Materiality-specific: Water
E13. Please provide details regarding the company’s water withdrawal and consumption (own operations) during the reporting period.
Linked to: ISAR B.1.3; CDP W1.2b (2022), CDP W1.2d (2022); SASB CG-HP-140a.1; GRI Disclosures 303-3, 303-5 (2018)
(Matrix – Text Boxes with option for Unknown or N/A)
Volume of water in megaliters
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Total water withdrawal:
Fresh surface water withdrawal:
Groundwater withdrawal:
Brackish surface water/seawater withdrawal:
Produced water withdrawal:
Third-party water withdrawal:
Percentage of water withdrawn in regions with high or extremely high water stress(%):
Total water consumption:
Fresh surface water consumption:
Brackish surface water/seawater consumption:
Produced water consumption:
Third-party water consumption:
Percentage of water consumed in regions with high or extremely high water stress(%):
Please provide additional explanation:
E14. Please provide details about the company’s water intensity of products in regions with high or extremely high water stress.
Linked to: CDP W1.3 (2022); CDP W1.3a (2022 )
(Matrix – Text Boxes with option for Unknown or N/A)
Cubic meter/$ OR cubic meter/product type (Please input a number e.g., 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Water intensity of products
Please provide additional explanation:
Materiality-specific: Forests, Biodiversity, and Land Use
E15. Please report the number and area (in hectares) of sites owned, leased, or managed by the company in or adjacent to protected areas and/or key biodiversity areas (KBA).
Linked to: GRI Disclosure 304-1 (2016); ISAR B6.1, WEF Common Metrics
(Matrix – Text Boxes with option for Unknown or N/A)
Number
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Sites
Hectares
Please provide additional explanation:
E16. What area (in hectares) of natural ecosystems was converted during the reporting period in areas owned, leased, or managed by the company?
Linked to: CDP F1.3 (2022); GRI Disclosure 304-1 (2016)
(Matrix – Text Boxes with option for Unknown or N/A)
Area (hectares)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Conversion of natural resources
Please provide additional explanation:
E17. Is the company supporting or implementing project(s) focused on ecosystem restoration and protection?
Linked to: CDP F6.11 (2022); GRI Disclosure 304-3 (2016)
(Matrix – Select one option or input a number per line)
No
No, but we plan to within the next 2 years
Yes, Project(s) area to date (hectares)
Forest ecosystem restoration
Other ecosystem restoration
Reforestation
Natural regeneration
Agroforestry
Set-aside land
Biodiversity offsetting
Please provide additional explanation:
Materiality-specific: Air Pollution
E18. Where applicable, please report the company’s emissions of the following pollutants during the reporting period.
Linked to: GRI Disclosure 305-7 (2016); ISAR B.1.4
(Matrix – Text Box with option for Unknown or N/A)
Emissions (t)
Unknown (Please provide additional information in the mandatory text box)
Not applicable (Please provide additional information in the mandatory text box)
NOx
SOx
Volatile organic compounds (VOCs)
Hazardous air pollutants (HAPs)
Particulate matter (PM10)
Persistent organic pollutants (POPs)
Other (Please provide additional information)
Please provide additional explanation:
Materiality-specific: Waste
E19. In metric tonnes, please report the company’s total weight of waste generated during the reporting period.
Linked to: GRI Disclosure 306-3 (2020); (partially linked to) ISAR B.2.1
(Matrix – Text Box with option for Unknown or N/A)
Waste generated (t)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Solid waste
Please provide additional explanation:
E20. Please report the percentage of the company’s waste that was hazardous waste (e.g., hazardous waste ratio) during the reporting period.
Linked to: GRI Disclosures 306-4, 306-5 (2020); ISAR B.2.3
(Matrix – Text Box with option for Unknown or N/A)
Hazardous waste ratio (%) (Please input a whole number e.g., 50% = 50)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Hazardous waste
Please provide additional explanation:
E21. Please report the company’s estimated metric tonnes of single-use plastic consumed wherever material along the value chain during the reporting period.
Linked to: WEF Common Metrics
(Matrix – Text Box with option for Unknown or N/A)
Single-use plastic (t)
Unknown
Not applicable (Please provide additional information in the mandatory text box)
Single-use plastics
Please provide additional explanation:
Overall Environment
E22. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to take to implement the environment principles, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for topics GRI 303 (2018), GRI 304 (2016), GRI 305 (2016), GRI 306 (2020), GRI 302 (2016)
(Text Box)
Swedfund works actively with regards to the climate both throughout the investment process and with portfolio companies. Swedfund has developed a climate lens, which means that all investments undergo an analysis in order to identify any significant climate risks, including both physical and transition risks, as well as an analysis of the climate impact that the investment is expected to generate. Most of Swedfund's portfolio companies have climate-related requirements in their investment agreements, and Swedfund works closely with the companies to assist them in driving the climate agenda themselves and adapting their operations to reduce the impact on the climate. Swedfund promotes active value creation among portfolio companies throughout the investment cycle. For more detailed information on challenges and initiatives see the climate section in Swedfund's Integrated Report 2022: https://ir.swedfund.se/
Anti-Corruption
Commitment
AC1. Does the company have an anti-corruption compliance programme?
Linked to: GRI Disclosure 3-3-c (2021) for the topic GRI 205 (2016)
(Radial – Select One)
No, it is not an immediate business priority
No, but we plan to within the next two years
Yes [Prompts AC1.1]
Please provide additional explanation:
For information, see Swedfund's Anti-Corruption Policy, which includes the requirements for Swedfund's anti-corruption management system as well as the requirements for portfolio companies' anti-corruption management systems: https://www.swedfund.se/media/2567/swedfund_anti-corruption_policy.pdf
AC1.1. If yes, in what year was this programme last reviewed? (YYYY)
(YYYY)
Programme last reviewed
Please provide additional explanation:
Swedfund's Anti-Corruption Policy is subject to annual reviews. Latest revision 2022.
AC2. Does your company have policies and recommendations for employees on how to act in case of doubt and/or in situations that may represent a conflict of interest, e.g., with regard to gifts and hospitality, donations, sponsorship, or interactions with public officials?
(Radial – Select One)
No, but we plan to within the next two years
No, and we have no plans to develop them
Yes, included within a broader policy or as a standalone policy
Please provide additional explanation:
This is covered by the following policies: Swedfund's Anti-Corruption Policy: https://www.swedfund.se/media/2484/swedfund-policy-for-sustainable-development_16-6-2021.pdf Swedfund's Code of Conduct: https://www.swedfund.se/media/2246/swedfunds-code-of-conduct.pdf As well as Swedfund's internal guidelines regarding gifts, invitations and other benefits.

Prevention
AC3. Who receives training on anti-corruption and integrity?
Linked to: WEF Common Metrics; GRI Disclosure 205-2 (2016)
(Select all that apply)
Select employees [Prompts AC3.1]
All employees [Prompts AC3.1]
Contractors [Prompts AC3.1]
Direct suppliers of the organization [Prompts AC3.1]
Indirect suppliers of the organization [Prompts AC3.1]
Other – such as partners, clients, etc. [Prompts AC3.1]
No training provided
Please provide additional explanation:
Regular training on anti-corruption is provided to all employees, the management team and the Board of Directors. For additional information please see Swedfund's Integrated Report 2022: https://ir.swedfund.se/, more specifically pp. 78-79, 144.
AC3.1. How often is such training provided?
(Matrix – Select one answer option per line)
One time only
Every two or more years
Every year
We do not collect this data
All employees
Please provide additional explanation:
Every new employee completes an e-learning on anti-bribery and corruption as a part of their introduction program. Additional trainings on the topic is provided regularly. For additional information please see Swedfund's Integrated Report 2022: https://ir.swedfund.se/
AC4. Does the company monitor its anti-corruption compliance programme?
Linked to: GRI Disclosure 3-3-e (2021) for the topic GRI 205 (2016); SDG Action Manager - SDG 16: Peace, Justice, and Strong Institutions
(Select all that apply)
Review topics on ad hoc basis
Yes, through internal employee self-evaluations
Yes, through automated controls monitoring
Yes, through external independent monitoring
Yes, through other mechanisms (Please provide additional information) [Makes text box mandatory]
No, we do not monitor the anti-corruption compliance programme (Please provide additional information) [Makes text box mandatory]
Please provide additional explanation:
With regards to portfolio companies, Swedfund conducts an anti-corruption and business integrity due diligence for all new investment opportunities. In addition, if there are gaps identified against the Anti-Corruption Management System requirements those are included in an ESG Action Plan that is being monitored during active ownership. Furthermore, Swedfund collects annual monitoring questionnaires from the portfolio companies, Swedfund acts in the boards and advisory committees of portfolio companies, and has an active ongoing dialogue including monitoring visits to portfolio companies. Internally, the Anti-Corruption Policy is being reviewed annually and possible needs for revisions are being discussed. All employees are expected to at least annually declare potential conflict of interests. Furthermore, Swedfund has a whistleblowing system and a grievance mechanism in place to be able to adequately investigate and respond to serious irregularities. Anti-corruption related information, the number of whistle-blowing and grievance cases and incident reporting from portfolio companies is being reported in the Integrated Report and subject to external audit. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/
Performance
AC5. Please report the company’s total number and nature of incidents of corruption during the reporting year. If applicable, please describe the nature of the incidents in the text box below
Linked to: GRI Disclosure 205-3 (2016); WEF Common Metrics; ISAR D.2.1
(Matrix – Text Boxes with option for Unknown or N/A)
Number of incident(s) (Please describe the nature of the incidents in the text box below)
Unknown
Choose to not disclose
Confirmed during the current year, but related to previous years
Confirmed during the current year, and related to this year
Please provide additional explanation:
The portfolio companies are contractually required to report serious incidents to Swedfund. During 2022, a total of 44 reports of serious incidents were received by Swedfund from portfolio companies, of which 19 originated from the underlying holdings of the funds. Examples of serious incidents include: fatalities, severe injuries which require medical care, occupational injuries suffered by a number of workers at the same time and incidents involving serious danger to life or health. Serious incidents also include adverse effects on human rights, fire, release of hazardous substances, strikes, various forms of harassment, corruption, fraud and theft. None of the serious incidents reported concerned incidents of confirmed corruption. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/
Response and Reporting
AC6. Within the reporting period, what measures has the company taken to address suspected incidents of corruption independently or in response to a dispute or investigation by a government regulator?
Linked to: GRI Disclosure 3-3-d (2021) for the topic GRI 205 (2016); Reporting Guidance on the10th Principle Against Anti-corruption – B3
(Select all that apply)
Initial case assessment
Internal investigation
Review by risk/ethics committee
Review by board of directors
External audit/review
Other (Please provide additional information) [Makes text box mandatory]
Not applicable/no incidents in the reporting period
Please provide additional explanation:
During 2022, two reports were received via the whistleblowing service, one of which was not investigated further. An investigation was carried out into the second report.
AC7. Does your company engage in collective action against corruption?
Linked to: GRI Disclosure 3-3-d (2021) for the topic GRI 205 (2016)
(Radial – Select One)
No, but we plan to within two years
No, it is not an immediate business priority
Yes (Please explain) [Makes text box mandatory]
Please provide additional explanation:
In partnership with Transparency International Sweden and five other Swedish investors (Folksam, the First Swedish National Pension Fund, SEB Investment Management, Skandia and the Church of Sweden), Swedfund was one of the founders of the Investors Integrity Forum, which is a platform where investors and Transparency International Sverige can jointly pursue key issues relating to corruption risks, acquire and disseminate knowledge, and promote transparency, integrity and accountability. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/
AC8. Briefly describe additional relevant practical actions the company has taken during the reporting period and/or plans to implement the anti-corruption principle, including goals set and any challenges faced and actions taken towards prevention and/or remediation.
Linked to: GRI Disclosures 3-3-c and 3-3-d (2021) for the topic GRI 205 (2016)
(Text Box)
Swedfund’s most significant corruption risks are linked to our investments. At the start of 2022, Swedfund launched the internal results from a study which summarised the most significant corruption risks in Swedfund’s largest markets and sectors. All of Swedfund’s portfolio companies are evaluated with regard to corruption risks. During 2022, Swedfund continued to work systematically to combat corruption. In partnership with Transparency International Sweden and five other Swedish investors (Folksam, the First Swedish National Pension Fund, SEB Investment Management, Skandia and the Church of Sweden), we have continued the collaboration within the framework of the Investors Integrity Forum, which is a platform where investors and Transparency International Sweden can jointly pursue key issues relating to corruption risks, acquire and disseminate knowledge, and promote transparency, integrity and accountability. Furthermore, Swedfund further developed its working methods and allocated additional internal resources to improve the risk analysis and the mitigation of corruption risks. All members of Swedfund’s Board of Directors, the management team and staff have undergone training regarding anti-corruption. Furthermore, all new employees have completed an e-learning course on anti-corruption as part of the introduction process. At the start of 2022, Swedfund’s Board of Directors, the management team and staff underwent an in- depth training concerning corruption and the most significant corruption risks. Additionally, Swedfund's internal guidelines regarding gifts, invitations and other benefit has been communicated throughout the organisation. For further information, see Swedfund's Integrated Report 2022: https://ir.swedfund.se/

Sustainability Reports*

Swedfund - IR2022 - Interactive Eng.pdf

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