About us
Pensum Asset Management AS is supervised by the Financial Supervisory Authority of Norway as an investment firm. You can read more about our licences, current legislation and how we handle personal data below.
This is an English translation for information purposes. In the event of any discrepancy, the Norwegian version applies.
2 March 2023
ESG – BACKGROUND AND PURPOSE
In recent years there has been increasing focus on and attention to ESG and sustainability in the financial markets. ESG means Environment, Governance and Social, where:
Environment concerns sustainability goals related to international targets set out in the Paris Agreement and the UN Sustainable Development Goals.
Social largely concerns requirements for working conditions, human rights, health, environment and safety considerations, anti-discrimination, etc.
Governance concerns good corporate governance and shareholder rights in the companies to be invested in.
The EU has chosen to regulate this by law through amendments to the sector legislation for regulated entities in the financial sector and rules on the reporting of non-financial information for companies, through the SFDR Regulation and the Taxonomy Regulation respectively. The changes in Norwegian law are implemented correspondingly through the Norwegian classification regulation and disclosure regulation.
ESG IN PENSUM ASSET MANAGEMENT AS
Responsible investments and sustainability
Pensum Asset Management AS strives to take sustainability risk into account when providing portfolio management and investment advice to clients.
In this context, sustainability risk means the risk of environmental, social or governance events or circumstances that may have an actual or possible material negative impact on the value of the investment. Sustainability factors mean environmental, social and employee matters, as well as matters relating to human rights and the fight against corruption and bribery.
Pensum Asset Management AS seeks to invest in and give investment advice on companies with high quality of governance and control and good quality of operations and management. The companies should focus on ethical issues and have a set of values for their business that is consistent with the guidelines. The companies should demonstrate good governance by complying with national legislation and international conventions, and by being open and comprehensive in their information to the outside world. This means that Pensum Asset Management AS seeks to take social conditions into account, including working conditions, human rights, health, environment and safety considerations, anti-discrimination and good corporate governance, when making investment decisions and providing investment advice, but has not committed itself to being bound by this in its management or advice.
Pensum Asset Management AS will take sustainability risk into account in its investment decisions without the company, the portfolios or the funds promoting environmental or social characteristics or having sustainable investments as their primary objective. Sustainability risk is assessed together with other types of risk in the various investments made. The return opportunities of the investments will be weighed against the risk taken, and the company will not choose sustainable investments over other investments with a better risk-adjusted return.
Pensum Asset Management AS does not currently consider the adverse impacts of investment decisions on sustainability factors at entity level. Individual funds or individual portfolios under management may consider adverse impacts on sustainability factors at product level, but the company wishes to follow the development of the regulations and the availability of information before deciding whether to include adverse impacts on sustainability factors at entity level. This position will be reviewed at least annually.
Pensum Asset Management AS will take sustainability risk into account in its investment advice in the same way as other risks are assessed for the individual products. The company will map clients’ sustainability preferences in connection with portfolio management and investment advice and, as far as possible, take these preferences into account when providing investment services and selecting products for each client.
Pensum Asset Management AS does not currently consider the adverse impacts of investment advice on sustainability factors at entity level and has not established separate sustainability criteria in the assessment of its product range.
Exclusion – investments
Pensum Asset Management strives as far as possible to exclude companies that contribute (or have contributed) to violations of fundamental ethical norms, produce certain types of weapons or base their business on coal production, tobacco production or similar (see the list below for a complete overview).
When excluding companies, Pensum Asset Management takes into account the exclusion list of the Government Pension Fund Global, which is decided by the Executive Board of Norges Bank based on input from the fund’s Council on Ethics.
Pensum Asset Management shall seek to avoid investing in companies that contribute to:
• Serious or systematic human rights violations
• Severe environmental damage
• Serious violations of the rights of individuals in situations of war or conflict
• Gross corruption
• Other particularly serious violations of fundamental ethical norms
• Unacceptable greenhouse gas emissions
• Production of weapons of the following types: cluster munitions, nuclear weapons and anti-personnel landmines
• Production of tobacco
• Sale of military equipment to certain states
• Production of pornography
Funds managed by Pensum Asset Management may have their own guidelines specific to each fund. Information about the funds’ guidelines can be found in the information material for each fund.
Sustainability and remuneration guidelines
Pensum Asset Management AS has remuneration guidelines intended to promote a long-term perspective and responsibility among employees and in the company. The guidelines shall promote good governance and control and shall counteract high risk-taking and conflicts of interest between Pensum and Pensum’s clients. Sustainability is an integral part of the remuneration guidelines, and high risk-taking within sustainability shall be counteracted in line with other risks the company is exposed to.
Follow-up and control of the guidelines
The Board of Directors of Pensum Asset Management AS has overall responsibility for the business, including the company’s strategy and guidelines for sustainability.
The company’s compliance function shall monitor compliance with the sustainability guidelines, including the necessary exclusion of companies.
More about the regulations and the environmental objectives
The green transition is in focus, and a key means of achieving the Paris Agreement’s goal of climate neutrality by 2050 is to move private capital into sustainable investments. As a measure to achieve this goal, the EU has adopted a comprehensive set of rules for sustainable finance. An important part of these rules is referred to as the taxonomy. The purpose of the taxonomy is to establish a common understanding of which economic activities and investments can be considered sustainable in line with the EU’s long-term climate and environmental objectives.
For an economic activity to be defined as environmentally sustainable under the taxonomy, it must:
• Contribute substantially to the achievement of at least one of the six environmental objectives
• Not do significant harm to any of the other environmental objectives
• Meet minimum safeguards for social rights
• Meet specified technical screening criteria
The six environmental objectives are:
• Climate change mitigation (reduction of greenhouse gas emissions)
• Climate change adaptation (measures to prevent/reduce damage related to climate change)
• Sustainable use and protection of water and marine resources
• Transition to a circular economy
• Pollution prevention and control
• Protection and restoration of biodiversity and ecosystems
26 June 2026
The Transparency Act – account of due diligence assessments (9 June 2026)
The Act relating to enterprises’ transparency and work on fundamental human rights and decent working conditions (the “Transparency Act”) shall promote enterprises’ respect for fundamental human rights and decent working conditions in connection with the production of goods and the provision of services, and ensure the general public access to information about how enterprises address adverse impacts on fundamental human rights and decent working conditions.
Pensum has prepared guidelines to embed responsibility in the business and to describe how Pensum identifies and assesses actual and potential adverse impacts on fundamental human rights and decent working conditions that the business has either caused or contributed to, or that are directly linked to the business’s operations, products or services through supply chains or business partners. The Board of Directors has overall responsibility for the guidelines.
Pensum is committed to respecting fundamental human rights and the ILO core conventions on fundamental principles and rights at work. Pensum shall offer decent working conditions and safeguard health, environment and safety in the workplace, as well as offer decent terms.
At least once a year, Pensum shall carry out a due diligence assessment of actual and potential adverse impacts on fundamental human rights and decent working conditions. The mapping of supply chains and business partners is risk-based. Factors taken into account include the nature and scope of the delivery, the size of the supplier, location, industry, Pensum’s ability to exert influence and other matters of significance for human rights or working conditions.
For the period 1 June 2025 to 31 May 2026, no matters or incidents have been identified that have actually had, or could potentially have had, significant adverse impacts on fundamental human rights or decent working conditions related to Pensum’s own operations or supply chains.
No actual adverse impacts requiring corrective measures have been identified. Pensum will nevertheless continue risk-based follow-up of suppliers and improve documentation for certain supplier categories, including cleaning/facility, canteen/catering, travel and event-related services, promotional items/textiles and card and travel expenses where the underlying suppliers are not directly apparent from the purchasing records.
Further information about Pensum’s work to safeguard human rights and decent working conditions is available on request.
Pensum Asset Management AS is supervised by the Financial Supervisory Authority of Norway (Finanstilsynet) and is licensed for cross-border activities in Sweden, Denmark, Iceland, Luxembourg, Spain, France, Germany and Austria.
Investment services, Securities Trading Act section 2-1 (1)
Ancillary services, Securities Trading Act section 2-6 (1)
Nominee in Norwegian registers of owners
The licence permits the following:
Click here to read more about Pensum Asset Management AS at Finanstilsynet (in Norwegian).
Pensum Asset Management AS (org. no. 920 704 050) is defined as a non-independent investment firm under MiFID II (“Markets in Financial Instruments Directive”).
All clients shall be classified under MiFID before a client relationship can be established. The purpose of this is to establish different levels of client protection based on knowledge of instruments/financial services and the ability to bear the risks involved. Clients shall be categorised in one of three categories: retail clients, professional clients or eligible counterparties.
Retail clients shall undergo a suitability assessment at the start of the client relationship based on information obtained from the client, and shall have an investment profile defined, which shall be updated at least annually.
Where the company receives remuneration from other product providers, it will not retain any part of the remuneration but will pass it on to the client, with the exception of the fee/administration cost charged by DNB to calculate the remuneration per client per fund.
This privacy statement describes how Pensum Group AS and its subsidiaries (“Pensum”) process information about our clients, visitors to the website pensumgroup.no, users of the iOS/Android app and enquiries Pensum receives by post, telephone and email.
Pensum depends on the trust of clients, partners and others, and we are committed to protecting your privacy. Your information shall be safe with us, and we will therefore inform you about what information we collect and how we protect your privacy.
1. What personal data do we collect?
Personal data is information that can be directly or indirectly linked to a natural person. This includes both electronic and physical documentation, as well as telephone recordings. Pensum provides investment services to private and corporate clients, and sends out newsletters and other marketing material. The personal data collected depends on the type of product or service you as a client are offered.
Identification information:
We collect national identity number, name and ID (passport, driving licence or similar) where we are required to do so by law.
Contact information:
We collect contact information to the extent necessary for the client relationship, e.g. address, telephone number, email or other.
Financial information:
Client and product agreements, transaction data.
Information required by law:
Pensum collects information required by law, such as screening against EU sanctions lists, tax information where necessary for the client relationship and basic information required in connection with Pensum providing investment services.
Special information:
Pensum is required by law to record telephone conversations about investment services.
2. Where do we collect the information from?
We collect information from:
3. What purposes is the information used for?
The information Pensum collects will be used for:
4. Disclosure of information
Pensum discloses necessary information to third parties in order to fulfil the company’s obligations to clients, e.g. to the custodian bank.
Pensum discloses information to public authorities when ordered to do so or required by law.
Pensum has entered into data processing agreements with suppliers, and our suppliers may not use the information for any purpose other than that for which it was collected.
We do not transfer information to countries outside the EU/EEA without the client’s consent.
5. Legal basis
Pensum must have a legal basis for processing personal data, and the company’s basis for collection is:
6. Your rights as a client
You have access to the information we hold about you and the right to data portability.
You have the right to request deletion of the information (within the limits of the law’s storage requirements).
You have the right to have incorrect information about yourself corrected.
7. Data controller
Pensum regards itself as the data controller, as the company has an independent purpose for collecting the information.
8. Contact
Contact compliance@pensumgroup.no if you have any questions.
