Code of Conduct

ÆRA Capital’s (“ÆRA”) focus on real estate debt investment management brings a significant impact on climate and individual lives, and therefore also a great responsibility. We aim to make a positive impact by considering sound business ethics throughout all our operations.

Cooperation with other parties is the very nature of our business. We prioritize working with consultants, financial partners, investors and suppliers and other business partners (collectively our “Business Partners”) who share our values and who have processes in place to ensure compliance with applicable laws and this Code of Conduct, in their own daily operations as well as in their supply chain.

This Code of Conduct (the “Code”) describes the ethical principles and business standards that apply to ÆRA, including employees and non-permanent staff, as well as our Business Partners.

If deemed necessary, ÆRA will take action against any violations of the Code, laws, or regulations. In the event of suspected unlawful activities, immediate measures will be taken. Where applicable, ÆRA will also report such matters to the relevant authorities.

Laws, regulations and business ethics

ÆRA shall comply with applicable laws, directives, regulations and standards, as well as any collective agreements relevant to its business activities, wherever business is conducted. Business activities are to be conducted in accordance with good business practice, and shall thus promote fair competition, maintain high ethical standards, as well as hold all relevant permits, licenses, and registrations.

No form of corruption, bribery, money laundering or unlawful restriction of competition is tolerated. Activities and gifts shall always be connected to the business relationship and characterized by transparency and moderation.

Human rights

ÆRA shall support and respect human rights, in accordance with the UN Declaration of Human Rights, and treat employees and suppliers fairly and equally.

ÆRA shall aim to work proactively against discrimination, harassment or threats based on age, race, gender, religion or other belief, sexual orientation, identity or expression, pregnancy, political opinions or disability.

ÆRA does not accept child labor or possible use of child labor. The minimum age of employment, under applicable legislation, shall be respected. Suppliers must not employ individuals under the age of 15, under the legal minimum age for work or under minimum age for completing mandatory schooling as specified by local laws, whichever is higher. Persons under the age of 18 must not be engaged in work that is or may be hazardous to their health or safety, including night work.

Working environment

ÆRA will strive to maintain a safe and innovative work environment. Safe and healthy working conditions shall be ensured for all employees, as well as the right to freedom of association and collective bargaining in accordance with local labor laws. Relevant information must be accessible in a language understood by the concerned individuals at work.

Environment and climate

ÆRA supports the reduction targets stated in the Paris Agreement and will continuously aim to reduce its operational greenhouse gas emissions within our own operations and supply chain to contribute to the efforts limiting the global temperature increase.

Conflict of interest

ÆRA has internal procedures to continuously identify potential and actual conflicts of interest. If such conflicts are identified, ÆRA will consider appropriate measures to mitigate and/or disclose them. If a conflict of interest arises, it will be handled in accordance with ÆRA’s internal procedures and, if necessary, referred to the company’s Board of Directors.

Information management

Confidential information or data concerning business activities or Business Partners may only be used for the purpose intended. Information regarding the purposes related to the processing of personal data can be found in our Privacy Policy. Information technology shall be reliable and developed in accordance with globally recognized ethical standards and comply with the General Data Protection Regulation (GDPR) and other applicable laws.

ÆRA shall proactively work against any type of misuse of insider information and employees are therefore not allowed to trade in instruments in listed real estate companies, nor engage in business which could be seen as competitive to ÆRA’s engagements.

ÆRA strives for an open and honest communication with all stakeholders. Knowledge sharing within ÆRA to improve our way of working is encouraged, but confidential information may only be shared within ÆRA on a need-to-know-basis.

This document is subject to regular review and updates to ensure its relevance and effectiveness.