Cubera Private Equity
Disclosures related to the Norwegian Transparency Act
BACKGROUND
The Norwegian Government has introduced the Transparency Act (No. Åpenhetsloven) with effect from 1 July 2022.
The act requires enterprises to, among other, carry out due diligence on the preservation of human rights and decent working conditions by establishing appropriate policies and procedures and assessing the risk of adverse impacts linked to the enterprise's operations, products or services via their supply chain or business partners. Enterprises must publish annually an account on how due diligence was carried out, including material risks which have been identified and actual adverse events which have taken place during the reporting period. The accounts are to be published on the company's website. The first reporting deadline is 30 June 2023.
Cubera Private Equity falls within the scope of the Transparency Act. As a wholly owned subsidiary of the Storebrand group, Cubera's accounts related to the Transparency Act are embedded in the Storebrand's report. The report has been reviewed and signed by the Boards of Directors and CEOs of all group companies, including Cubera.
A summary of Cubera's transparency accounts is provided below. A link to the original report can be found on the bottom of the page (external website).
SUMMARY OF CUBERA’S ACCOUNTS RELATED TO THE TRANSPARENCY ACT
Cubera is an investment manager and advisor whose suppliers deliver normal products and services as should be expected for an ordinary office environment. These include but are not limited to office premises, cleaning and maintenance, office supplies and groceries, IT services, accounting and payroll, compliance and legal services, and data systems and intelligence.
Cubera has conducted a risk analysis of its suppliers and business partners with regards to risk of human rights violations. The majority of products and services acquired by Cubera are of such nature that the risk of human rights breaches is considered to be low or negligible. Some services, such as cleaning and maintenance services, generally carry a higher inherent risk of breaches related to labour arrangements and working conditions. Cubera acquires cleaning and maintenance services from authority-approved and/or certified suppliers. No human rights or working conditions breaches have been registered among Cubera's suppliers in the period.
Cubera delivers investment advisory services in the form of investment recommendations to the Cubera funds. The Cubera funds' investees are private equity funds managed by reputable private equity managers. Evaluation and mitigation of ESG risks, including human rights risks, consists in understanding and aligning the manager's policies and management approach, with Cubera's principles. When doing secondary transactions, assessing the risks in the portfolio of companies to be acquired is also crucial. Thanks to this consistent and thorough process, Cubera considers the risk of human rights breaches in the investment portfolio to be generally low.
Cubera monitors all its investments for human rights abuses through the data provider RepRisk and through reporting from the managers of the underlying investment portfolio. Cubera has not registered material human rights breaches in the reporting period. Should a breach be detected, Cubera will contact the responsible fund manager to address the issue and, where possible, contribute to solving the breach.
Cubera is a signatory of the UN Principles for Responsible Investment (PRI).
Open the Storebrand Group’s transparency report →
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A section on Cubera can be found on page 20 of the report.
