Sustainability-related disclosures under the SFDR

Last updated: 2 October 2026

Compliance

Summa Equity AB (“Summa”) makes the following disclosures in accordance with Articles 3(1), 4(1)(a) and 5(1) of the Sustainable Finance Disclosure Regulation (2019/2088) (“SFDR”). Links to further information on our approach and impact assessments are provided.

Summa Equity AB

Summa seeks to invest to solve global challenges. We invest solely in companies whose core business contributes positively to one or several sustainability factors. To enable this, sustainability factors are integrated as tools for value creation across all stages of the investment lifecycle, from sourcing, through screening and due diligence, into the ownership period and eventually the sale of the company (exit). Sustainability risk assessment and follow-up are integrated across all funds managed by Summa.

We invest thematically across four areas: Circularity, Energy Transition, Sustainable Food and Tech-Enabled Resilience. Within each theme we invest in companies that aim to contribute to solving defined environmental or social challenges, with intended outcomes articulated through our thematic theories of change.

“Sustainability factors” is defined within the SFDR as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. Summa will in addition consider other sustainability factors where material (for example data security and privacy).

Fund classifications under the SFDR

Summa’s funds are classified as follows:

• Summa Equity Fund I and Summa Equity Fund II are classified as Article 8 funds, promoting environmental and social characteristics and investing in companies that follow good governance practices.
• Summa Equity Fund III and Summa Circular are classified as Article 9 funds, with sustainable investment as their objective.

Our strategy includes companies that are critical from a systems-change perspective but that may not qualify as “sustainable investments” (as defined under Article 2(17) SFDR) at the time of entry. In such cases our active ownership model is central: through governance, strategic direction and operational development we seek to materially increase each company’s positive contribution to its theory of change over the ownership period. Sustainability risks are identified, assessed and managed throughout the investment lifecycle, and principal adverse impacts are considered and reported.

Fund-specific SFDR disclosures are published on the investor portal together with other information relating to each fund.

Fund-specific SFDR disclosures are published on the investor portal together with other information relating to each fund.

Our impact investment approach

All investment opportunities are assessed across three impact dimensions:

• Impact alignment: the core environmental or social challenge the company addresses, mapped to one or more of Summa’s thematic theories of change and, where applicable, assessed against the EU Taxonomy (Taxonomy alignment is not a prerequisite for investment).
• Impact contribution: whether and how the company contributes to solving the identified challenge beyond baseline market activity, evaluated using Summa’s internal impact framework, which integrates contribution to the theory of change with an assessment of risks to impact, in line with SFDR requirements.
• Sustainability fundamentals: whether the business meets minimum sustainability standards, including assessment of the risk of causing significant harm (through relevant Principal Adverse Impact indicators and Do No Significant Harm considerations) and basic good governance expectations.

Our due diligence process is founded in the OECD Due Diligence Guidance for Responsible Business Conduct, to ensure fit-for-purpose impact and sustainability due diligence in each investment case.

Assessing and integrating sustainability risks

Sustainability risk means an environmental, social or governance event or condition that, if it occurs, could potentially or actually cause a negative material impact on the value of the investments made for the account of a fund and thus on the value of the interests issued by such fund. Sustainability risks are initially assessed alongside other types of risk as part of a rigorous due diligence process, involving for example interviews with management, industry research, review of performance history, environmental and HR data, and organizational and strategic evaluations. We typically work with external consultants and experts when we carry out these assessments. Different environmental, social and governance issues are prioritized in due diligence depending on materiality to the business, materiality to the broader set of stakeholders, and the level of impact.

The output from due diligence, including information on material sustainability risks, forms part of the investment material sent to the Investment Committee, which is responsible for screening and evaluation of potential investments prior to making a recommendation to the Board of Directors. As with concerns about the level of financial returns, a determination that there are material adverse impacts or sustainability risks that cannot be solved or mitigated will result in a decision not to invest.

An investment may proceed where we are confident that risks are at an acceptable level and can be mitigated or solved over time, provided the company demonstrates suitable characteristics in terms of impact alignment and impact contribution as well as the potential for strong financial returns. Once an investment has been made, Summa monitors sustainability risks on a regular basis.

Governance

Impact and sustainability considerations are integrated throughout the investment lifecycle. The Investment Committee evaluates potential investments and exits, including material sustainability factors, and makes recommendations to the Board, which takes final decisions. A dedicated Impact team supports and strengthens Summa’s sustainability and impact focus across the entire investment lifecycle, and our Via Summa team supports portfolio company boards and management throughout the ownership period. Summa’s risk management function, led by a dedicated Risk Manager, analyzes the risk profile of Summa and the Funds annually, with significance assessed quarterly and presented to the Board in a quarterly Risk Report.

Code of Conduct

All Summa Equity employees (“Summates”) are expected to adhere to our corporate values, and high standards of ethical business conduct as outlined in our Code of Conduct. Summa’s values are Openness and honesty, Authenticity, Responsibility, Entrepreneurial, and Respectful.

Remuneration policy

In accordance with the Summa Remuneration Policy, all identified staff and Investment Professionals are remunerated as employees, with a combination of fixed and variable remuneration.

For Summa, sustainability risks and opportunities are naturally integrated in the investment process for all funds, since Summa’s investment thesis is based on using sustainability factors as a screening tool and, following an investment, using the same factors as value creation levers.

The policy seeks to ensure that identified staff and Investment Professionals are encouraged to consider the long-term effects of their decisions and avoid taking short-term risks to achieve personal gain. This is achieved, among other things, by basing the performance assessment for variable remuneration on a longer period. Considering the checks and steps implemented to deter excessive risk-taking, the prudent balance between fixed and variable remuneration, and the fact that sustainability impacts, risks and opportunities are naturally integrated in Summa’s business, the policy ensures the promotion of sound and effective risk management with respect to sustainability risks.

Statement on principal adverse impacts of investment decisions on sustainability factors

Policies on due diligence and the identification and prioritization of principal adverse sustainability impacts and indicators

Summa considers principal adverse impacts of its investment decisions on sustainability factors. Issues are prioritized according to materiality to the individual investee company and to the portfolio as a whole. This is first done during due diligence (pre-investment) and then re-evaluated regularly during the ownership phase. Targets are typically set for the portfolio as a whole, and for individual companies in dialogue between management, the Board of Directors and Summa deal teams.

Principal adverse sustainability impacts

The portfolio-wide principal adverse impacts are emissions of greenhouse gases (GHG) and supply chain biodiversity impact, while certain individual investments also generate significant amounts of waste and use substantial amounts of fuel and energy. The most prominent adverse impact from our current portfolio is GHG emissions, particularly Scope 3. In 2025, portfolio-wide greenhouse gas emissions were approximately 2.5 million tCO2e, with Scope 3 the largest share at approximately 2.0 million tCO2e, while estimated avoided emissions enabled by our portfolio companies’ products and services were approximately 3.4 million tCO2e. Summa’s position is that the negative impact cannot be “netted” against the positive impact. The adverse impact must be managed effectively and reduced over time. Summa is actively working on strategies to manage these impacts effectively and reduce them over time, e.g. by engaging with the portfolio companies’ management on sustainability matters, by setting relevant targets and by monitoring the adverse impacts over time.

Please also see our annual Portfolio Report [and PAI reporting] for further information.

Engagement policy

Summa has adopted an Engagement Policy which outlines the principles for Summa’s shareholder engagement and describes how Summa integrates shareholder engagement in its investment strategy. The Engagement Policy sets out that Summa shall integrate ESG into ownership policies and practices (including appropriate ESG disclosures) in portfolio companies. Summa will generally be an active owner, exercising its voting rights in the best interest of the funds and taking an active role in the strategic development of portfolio companies. To influence portfolio companies and promote better corporate governance, risk management, performance or disclosure standards, Summa will generally cooperate and communicate with other shareholders. Summa has also adopted a conflict of interest policy to take all reasonable steps to prevent and manage conflicts of interest.

Adherence to business conduct codes and internationally recognized standards

Climate and nature

Summa has a long-standing ambition to align its portfolio with the Paris Agreement’s 1.5°C target. To meet this ambition, we have committed to the Science Based Targets initiative to set validated climate targets across the portfolio. We track and disclose the carbon footprint (Scope 1 to 3) and biodiversity impact of Summa and our portfolio companies on an annual basis, in line with the Greenhouse Gas Protocol, and we actively engage in dialogue with portfolio company boards and management on how to achieve their climate targets. Our Via Summa Climate Action Program supports portfolio companies through carbon accounting, target setting and the implementation of decarbonization roadmaps.

Adherence to international standards for risk integration and due diligence

Summa is a signatory of the Principles for Responsible Investment (UN PRI), which include a commitment to integrate ESG into ownership policies and practices and to seek appropriate sustainability disclosures from investee companies. Respect for internationally proclaimed human rights is integrated into our policies, and we monitor that this is also integrated into the policies of our investees, drawing on the UN Guiding Principles on Business and Human Rights. We seek to adhere to the ten principles of the UN Global Compact, whose four themes (Human Rights, Labor, Environment and Anti-Corruption) are integrated into our Code of Conduct. Our due diligence is founded in the OECD Due Diligence Guidance for Responsible Business Conduct and the OECD Guidelines for Multinational Enterprises, and we apply ILO core conventions.

Evolving regulatory frameworks

Summa is not directly covered by the EU Corporate Sustainability Reporting Directive (CSRD) but supports portfolio companies that are directly or indirectly affected, including through training and reporting support, and has implemented the categories of the European Sustainability Reporting Standards (ESRS) in our pre-investment assessment framework. We monitor and prepare for developments including the EU Taxonomy, VSME reporting and forthcoming SFDR 2.0 reporting standards. We also seek to align our Portfolio Report with leading international standards and frameworks, including the International Sustainability Standards Board (ISSB), the Task Force on Climate-related Financial Disclosures (TCFD) and the Taskforce on Nature-related Financial Disclosures (TNFD).

Certification and collaboration

Summa is a Certified B Corporation. Certified B Corps are expected to meet high standards of verified social and environmental performance, transparency and accountability. We collaborate with peers, investors and other stakeholders to strengthen responsible and impact investment practices, including as members of the UN PRI and the Global Impact Investing Network (GIIN), and through participation in the Nordic Responsible Investment Forum.

Whistleblowing and remediation

Summa has implemented a publicly available whistleblowing channel through WhistleB, accessible at https://report.whistleb.com/en/summaequity, for internal and external stakeholders to report objectionable conditions in our organization or among our portfolio companies, including breaches of our Code of Conduct, corruption, environmental damage, and infringement of human or labor rights. No reprisal of any kind is tolerated against justified complainants. Where human rights violations are identified, Summa is committed to participating in rectifying harm and ensuring corrective actions are executed.

Giving back: Summa Foundation

Approximately 10% of the surplus from Summa Equity is distributed to the Summa Foundation, an independent charitable foundation that supports social and environmental causes, focusing on issues such as education, gender inequality, biodiversity loss, climate change and support for disadvantaged individuals.

Fund-specific disclosures

Summa’s fund-specific SFDR disclosures are published on the investor portal together with other information relating to such funds.