Sustainability Policy

This policy applies to all employees in Pareto Securities AS with subsidiaries (“Pareto Securities”). The policy establishes the principles to keep environment, climate and social conditions at the forefront of our internal and external activities.

This Policy sets out the approach of Pareto Securities AS, including subsidiaries and branches (“Pareto Securities” or the “Group”), to managing environmental, social, and governance (ESG) considerations in our own operations and in the services we provide. The Policy applies to all employees and officers across the Group. Implementation may vary by jurisdiction depending on applicable local laws, operational context, and the relevance of specific sustainability risks.

Our aim is to take responsible and proportionate steps to:

• reduce the environmental impact of our operations
• manage sustainability-related risks in our business activities
• support clients and investors in understanding sustainability considerations where relevant to markets, sectors, or investment decisions, and
• meet applicable regulatory requirements, including EU MiFID II sustainability obligations where relevant.

This Policy is designed to be practical, achievable, and reflective of our current maturity level, while supporting gradual improvement over time.

Pareto Securities’ approach to sustainability is informed by:

• internationally recognised frameworks such as the UN Global Compact, UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Multinational Enterprises, and
• applicable regulatory requirements across our jurisdictions, including MiFID II sustainability rules and local environmental and labour laws.

These standards guide our efforts without implying full alignment or advanced implementation across all entities. We apply these frameworks as reference points, adapted to the nature of our services, our operational footprint, and our proportionate ability to influence outcomes.

We acknowledge that good performance in one area does not offset adverse impact in another, and we aim to improve our practices over time.

Pareto Securities’ direct environmental footprint is primarily related to business travel, offices, and IT infrastructure. We aim to reduce environmental impacts in a proportionate and practical manner.

3.1 Energy Use and Buildings

We will work to:

• promote energy-efficient operations,
• consider sustainability-related factors when engaging with landlords, and
• encourage reasonable conservation measures in our offices.
   

3.2 Travel

Travel plays an important role in our business model. We aim to reduce unnecessary travel by:

• encouraging the use of video conferencing where practical,
• considering alternatives to air travel for shorter trips where feasible, and
• raising awareness internally of the environmental impact of travel.

These expectations will be applied proportionately and with consideration for business needs and regional differences.
 

3.3 IT Infrastructure and Data Centers

We will engage with key IT and data-center providers to understand their approach to:

• energy efficiency,
• renewable-energy use, and
• optimisation of data storage and processing.
   

3.4 Waste and Resource use

Where feasible across our offices, we will:

• encourage recycling and responsible waste handling,
• reduce unnecessary printing,
• promote reasonable measures to limit food waste, and
• reduce the use of disposable items.

These measures may vary by office depending on available facilities, local infrastructure, and operational needs.

Pareto Securities engages suppliers across multiple jurisdictions. We aim to integrate sustainability considerations into procurement processes in a proportionate and risk-based manner. We will:

• consider environmental and social factors when selecting and evaluating key suppliers
• communicate relevant expectations to key suppliers, and
• seek documentation from higher-risk suppliers where appropriate.

We recognise that our ability to influence suppliers varies and will focus efforts where our leverage is meaningful.

As an investment bank, our most significant sustainability influence is indirect, through advisory services, capital-raising activities, research, and investor interactions.
 

5.1 MiFID II Sustainability requirements

In jurisdictions where applicable, we will:

• take sustainability preferences into account as required by MiFID II when providing investment advice,
• consider relevant sustainability risks in the suitability assessment where they may affect the risk/return characteristics of a financial instrument or client objectives, and
• provide the required explanations to clients regarding sustainability-related products
   

5.2 Research

Our research teams may include links to sustainability information published by the companies we analyse, allowing clients to access issuer-provided disclosures directly. This is done for transparency and does not constitute an assessment of sustainability risks or preferences under MiFID II.

Research is produced independently and is not tailored to individual client sustainability preferences.
 

5.3 Advisory services

When advising clients, including issuers and companies in traditional industries, we aim to:

• discuss sustainability-related trends when relevant to investor expectations,
• consider material sustainability risks as part of broader sector and jurisdiction assessments,
• encourage transparency where appropriate.

We recognise that our role is advisory and does not give us control over clients’ sustainability performance.
 

5.4 Market opportunities

Pareto Securities operates across the full energy spectrum, including both traditional energy and renewable sectors. Our role is to support clients and investors by providing informed, market-driven advice that reflects sector dynamics, regulatory developments, and investor expectations. We aim to:

• support capital-raising and advisory activities in renewable energy and clean-technology sectors, building on our long-standing presence in these markets,
• monitor and respond to evolving investor interest in sustainability-related themes, and
• provide clients and investors with relevant market insights, including where sustainability-related factors influence  sector developments or investor demands.

This approach enables us to participate responsibly in market opportunities while recognising the diverse priorities of our client base and the ongoing transition across global energy markets.

Pareto Securities prepares an annual ESG report that provides an overview of relevant environmental, social, and governance topics for the Group, including information on CO₂ emissions and selected sustainability-related measures. The report is prepared on a voluntary basis, as the Group is not currently subject to the CSRD or equivalent frameworks.

The Board of Directors is briefed on the content of the ESG report prior to its publication. Once finalised, the report is made publicly available on our website. Where required by applicable laws or regulations, additional sustainability-related disclosures will be provided in a proportionate and context-appropriate manner.

• Employees are expected to take reasonable steps to act in line with this Policy
• Managers are responsible for promoting awareness and implementing relevant measures within their teams
• Compliance and Risk support regulatory implementation, including MiFID II sustainability requirements.
• Executive Management oversees the overall sustainability framework and continuous improvement efforts.

Pareto Securities will review this Policy periodically and adjust it in light of evolving regulatory expectations, market developments, and organisational maturity. Improvements will be made incrementally and proportionately.