Legal and regulatory

HitecVision is subject to the EU’s Sustainable Finance Disclosure Regulation (SFDR). The documents below provide the mandatory disclosures under the SFDR, and will be updated as required by the regulation.

HitecVision is committed to fostering a culture of ethical and responsible business conduct, and to ensuring that its activities are conducted in accordance with leading standards. Our Business Partner and Supplier Code of Conduct sets forth the basic conduct and behaviour that HitecVision expects and requires from all its suppliers and business partners.

HitecVision is committed to fostering a culture and a general conduct of respect for internationally recognised human rights and seeks to avoid causing or contributing to any adverse human rights impacts of our own or through our portfolio companies and other business relationships. Our Human Rights Policy applies to all employees of HitecVision, as well as our affiliates. 

Concerns about human rights impacts can be raised through our grievance procedure.

HitecVision is subject to the Norwegian Transparency Act relating to enterprises’ transparency and work on fundamental human rights and decent working conditions. Pursuant to the Transparency Act, HitecVision carries out due diligence in accordance with the OECD Guidelines for Multinational Enterprises and annually publish an account of the due diligence assessments. The account is published in Norwegian.

Managers of alternative investment funds shall in accordance with the Norwegian Act on the Management of Alternative Investment Funds, section 4-7, implementing Directive (EU) 2017/828 (Shareholders’ Rights Directive), either disclose a shareholder engagement policy that describes how HitecVision Advisory AS integrates shareholder engagement in the investment strategy or disclose an explanation of why HitecVision Advisory AS does not have a shareholder engagement policy.

HitecVision Advisory AS has chosen not to develop or publish any shareholder engagement policy since the funds managed by HitecVision Advisory AS have a strategy of investing in the European energy sector, where the equities of the companies generally are not listed on any regulated market, as defined in Article 4 of Directive 2014/65/EU (MiFID II).

It is not within the funds managed by HitecVision Advisory AS’ primary investment strategy to invest in equities listed on regulated markets and the funds have limited access to make investments in listed equities. The investment of the funds may from time to time be listed on a regulated market, generally as part of a public to private process or an ongoing exit process. HitecVision Advisory AS does not deem it necessary or proportionate to have a shareholder engagement policy due to the limited circumstances where the funds have investments in equities listed on regulated markets. HitecVision Advisory AS will assess on an ongoing basis whether it is appropriate to develop and disclose a shareholder engagement policy.