Norwegian Financial Supervisory Authority finds misleading PRI sustainability branding and missing PAI disclosures at Njord Alternative Investments

The Norwegian Financial Supervisory Authority published an inspection report on Njord Alternative Investments AS as part of a thematic, document-based review of eight fund managers’ compliance with sustainability-related disclosure requirements. The supervisor identified deviations from the sustainability disclosure regime, focused on website marketing and required disclosures on principal adverse impacts. The review found that the firm used a “Signatory of PRI Principles for Responsible Investments” logo on its website in a way that could create expectations that the funds promote environmental or social characteristics, while the firm at the time stated it only managed funds subject to Sustainable Finance Disclosure Regulation (SFDR) Article 6 disclosures and not Article 8 or 9 products. Finanstilsynet concluded that such branding, absent corresponding SFDR commitments and measurement, made the marketing misleading, and noted it had not received documentation showing PRI commitments were operationalised for funds available at the time of the inspection; the logo was subsequently removed. The supervisor also found the firm had not published the “comply or explain” disclosures required under SFDR Articles 4 and 7 on how principal adverse impacts (PAI) are considered, or why they are not; the firm later published a statement (dated 16 June 2025) explaining that it does not consider PAI at product level, and Finanstilsynet highlighted that the disclosure obligations apply both at firm level and for each fund. Finanstilsynet asked Njord Alternative Investments to send a copy of the inspection report to its auditor and depositary.