Guidelines for responsible ownership and good cooperate governance

Active ownership and transparency in private equity funds 2021

Foreword to Active Owners Denmark’s guidelines 2021
As an industry association, Active Owners Denmark gathers the entire ecosystem of active
ownership and investors in Denmark. Our industry counts everything from private investors to
family offices, venture capital- and private equity funds, large pension funds as well as all the
actors who advise them. In September 2021, the association changed its name from the former
DVCA to Active Owners Denmark. To a greater extent, the name should reflect what we do as an
association: Our members provide active ownership in the companies in which they invest and help
to develop Denmark’s next generation of successful companies.

However, these guidelines only apply to private equity funds, which in 2008 experienced
significant political pressure from the society surrounding them. Active Owners Denmark aimed at
that time, and still want to emphasize that we do expect transparency and accountability in the
industry. In addition, we aim to exercise ownership in portfolio companies responsibly as well. To
reflect a changing society both within and outside the country, Active Owners Denmark’s
guidelines for responsible ownership and good cooperate governance require continuous
updating. The latest update took place in 2019 and the 2021 edition is now available. The
guidelines apply to both private equity funds and the companies in which they invest. Additionally,
the guidelines involve recommendations in regard to communication strategies. Thus, these
guidelines represent a collective expression of “best practice” for responsible ownership and good
corporate governance in private equity funds that are members of the association and the
companies that the private equity funds own. However, these recommendations are not sufficient
in themselves. They must be perceived in connection with the requirements set by legislation such
as the Danish Companies Act, the Danish Financial Statements Act as well as additional FAIFregulation.

The aim is to provide the guidelines with the degree of flexibility necessary for them to be
applicable to the society in which the private equity funds and their companies operate. The
recommendations are thereby characterized by continuous changes in frameworks and the industry’s dialogue with surrounding environment. The is thereby intended that the need to revise
the guidelines should be considered on an ongoing basis.
In this regard, a recommendation has been incorporated into the 2021 guidelines for the private
equity fund to generally describe its diversity strategies for management along with its climate
policy in order to reduce its CO2 emissions significantly. Private equity funds in Denmark take
climate responsibility seriously and believe that society should expect a lot and rapid action from
coming from them.

The guideline takes into consideration that there are differences between private equity funds and
their companies. This means that responsible ownership may be exercised differently in the
respective funds and companies. However, it is the assessment of Active Owners Denmark, that
the guidelines take the place of comprehensive regulation of the sector.

Active Owners Denmark intends for these guidelines to be an applicable tool. Both for the private
equity funds they cover as well as the funds they do not. Active Owners Denmark thereby
encourages all non-covered private equity funds and private equity-backed companies to make
use of these guidelines as inspiration for their work in society.

In 2021, Active Owners Denmark launched its tax code. The tax code should be perceived as a
supplement to these guidelines. With our tax code, we aim to reflect that our members pay the
taxes, they should, and that they work constructively with the tax authorities in the countries in
which they work. We are also aware, that it is important for many of our members to be able to
prove to investors etc., that they comply with responsible tax behavior. The tax code provides that
opportunity as it sets clear standards that are very close to the standards under which the pension
funds work. Active Owners Denmark’s tax code can be found here: https://aktiveejere.dk/aktiveejeres-kodeks-for-ansvarlig-skatteadfaerd/.

Copenhagen, December 1, 2021

Jan Johan Kühl
Deputy Chairman, Active Owners Denmark
Chainman, Active Owners Denmark’s Private Equity Committee

Christian Frigast
Chairman, Active Owners Denmark

Introduction

1. Target group

The target group for these guidelines is primarily Danish private equity funds and foreign private
equity funds operating in Denmark along with the companies in which these funds have invested.
The guidelines are also expected to be of interest to investors in the respective funds, employees,
creditors, advisers, and public authorities. In addition, the public may also have an interest in
gaining insight into how private equity funds in Denmark operate.

2. Active Owners Denmark’s Private Equity Committee

The sender of these guidelines is Active Owners Denmark’s Private Equity Committee. The
committee works to create optimal framework conditions and a healthy investment environment
for private equity funds in Denmark. The committee also works to expand awareness of private
equity-owned companies in Denmark.
In regard to the guidelines, the committee has followed the development of good corporate
governance both nationally and internationally and strived for continuity in the work with
responsible ownership and good corporate governance in Danish private equity funds. This work
ensures that the recommendations are appropriate for Danish private equity funds and their
companies.

3. Soft law and its significance

The recommendations within these guidelines are so-called “soft law” and thus more flexible than
actual legislation (“hard law”). While regulation by law typically describes a minimum standard that
sets the framework for companies’ conduct, soft law reflects “best practice.” Furthermore, soft law
is characterized by a high degree of voluntariness, which provides the present recommendations
the flexibility which is needed for the association’s members and their portfolio companies in order
to adapt the principles to the circumstances.
Soft law is by definition more dynamic than traditional legislation, as it is easier to adapt to
changes in affected areas. This allows the recommendations to be up-to-date at all times. Soft law
is often an alternative to traditional legislation and well-functioning soft law can be helpful to avoid introducing actual regulation in areas where flexibility is needed in order to continuously adapt
regulation to fit societal development.
It is registered in Active Owners Denmark’s Articles of Association, § 7 subsection 1, that noncompliance with these guidelines may lead to exclusion of a Private Equity member of the board
of directors.

4. ’Comply or explain’ principle

As the guidelines for listed companies, which are published by the committee on corporate
governance, Active Owners Denmark’s guidelines are based on the “comply or explain” principle. It
is a general expectation that the private equity funds and their portfolio companies basically
comply with these guidelines and that they consist as a suitable instrument for increasing the
general level of information. This approach also reflects that Active Owners Denmark aims to
promote self-regulation rather than “hard law” as we recognize that private equity funds are
already subject to extensive regulation.

With a written request, Active Owners Denmark will respond to the respective private equity fund
in cases where the guidelines are not complied with. Furthermore, Active Owners Denmark’s
Articles of Association addresses sanction options in case of a member through its activities harms
the association and its interests or does not comply with the guidelines for good corporate
governance. Active Owners Denmark’s Articles of Association can be read here.
https://aktiveejere.dk/aktiveejeres-vedtaegter/.

5. How are the guidelines structured?

These guidelines are structured as follows. Section 1 presents and defines active ownership in
private equity funds and the fund’s portfolio companies. Next, section 2 presents an overview of
significant changes in these guidelines – compared to the 2019 edition. Section 2 also defines the
entry into force and which companies and funds the guidelines apply to. Section 3 identifies the
guidelines applied to private equity funds, and section 4 identifies the guidelines at the corporate
level. Section 5 explains the content of the annual follow-up report by Active Owners Denmark.

I. Active ownership in private equity funds

That a private equity fund exercises active ownership mean that the fund – as owner –
collaborates with the company’s board and management in order to develop the company. The private equity fund exercises active ownership on behalf of its investors to increase the value of
the firm and thereby create a return for the investors.
The private equity fund usually acquires the majority of the shares in the companies in which they
invest, in order to gain control over the strategic decisions. The active ownership is then usually
exercised by means of a simple governance structure, which typically includes the private equity
fund, the board of directors, and the management, cf. figure 1 below.

Figur 1: Ledelsesstrukturen i en kapitalfondsejet virksomhed

Practically, active ownership usually includes the following elements

a) The private equity fund is represented on the board of directors, typically as deputy chairman. In
terms of governance, the private equity fund usually respects the mandate of the day-to-day
management very carefully.

b) The private equity fund sets requirements for the company’s ongoing financial reporting, which
ensures a high degree of transparency and insight into the business development. Thus, there is a
contentious follow-up on the financial development and execution of the company’s business plan.

c) The private equity fund often makes its own employees or external advisers available to the firm
in order to ensure that specific tasks are solved. This may, for example, be in regard to further
acquisition, raising capital, etc.

d) Typically, it is the private equity fund (in collaboration with the chairman of the board) that
takes the initiative for replacements in the company’s management if necessary.

e) As part of the exert of active ownership, the private equity fund maintains sufficient capital
resources in order for additional capital to be invested in the company if such need arises.

f) The private equity fund will usually cause the management and occasionally the board of
directors to become co-owners of the firm. This strengthens the common interest between the
private equity fund, the management, and the board of directors, and from experience, it supports
the value creation in the private equity fund-owned company.

g) Usually, the period of ownership is limited to between 3 to 7 years, which is when the value
creation must take place. It creates a “sense of urgency” among the parties involved –
management, board of directors, and the private equity fund. In order to efficiently utilize the time,
a development plan that contains value-creation initiatives is implemented for the company. The
plan is developed in close collaboration between the private equity fund, the board of directors,
and the management.

II. Who does the guidelines cover, entry into force, and
significant changes

1. Which private equity funds are covered

A private equity fund is covered by the guidelines if (all requirements must be met):

The fund is a member of the association
Has assets under management of at least DKK 500 million. (Calculated as the total commitment
of all funds managed by a given management company) and which invest directly in companies.
Has a company structure in which one or more investors (limited partners) are included.
As a rule, makes majority investments.

Asset managers that are members of Active Owners Denmark whose ultimate parent company is
domiciled in a country other than Denmark cannot be fully obliged to comply with the guidelines,
as they may be subject to other guidelines that apply where the company is registered.

The foreign private equity funds’ activities that can be attributed to Danish investments are in line
with the Danish private equity funds covered by the guidelines in chapter 3, sections 1-5. Funds
that are covered by the guidelines can be found here:
https://aktiveejere.dk/retningslinjer-for-ansvarligt-ejerskab-og-god-selskabsledelse/

2. Which private equity-owned companies are covered?

A private equity-owned company covered by these guidelines is a Danish company (whose parent
company is Danish as well) and which:

Is controlled by one or several Danish or foreign private equity funds, which are members of
Active Owners Denmark (regardless of whether these funds are covered by the guidelines or not,
cf. above).
As a minimum, have a size that entails a classification as a large class C company in accordance
with the Danish Financial Statements Act. The limits for a large class C company are per. January 1, 2022:
> Turnover greater than DKK 313 million
> Balance sheet total greater than DKK 156 million
> Number of employees exceeds 250

3. Entry into force

The updated guidelines will enter into force for the fiscal year starting January 1, 2022, or later.
The guidelines at the fund level enter into force immediately. Until these guidelines are fully
phased in, the guidelines published by Active Owners Denmark in 2019 will remain in force.

4. Significant amendments to the bill:

In accordance with Active Owners Denmark’s promise to continuously revise the association’s
guidelines regarding active ownership and transparency in private equity funds, the Private Equity
Committee revised the guidelines in 2021. The most important amendments are:

Further tightening of the guidelines regarding the tasks and responsibilities of the Board of
Directors, e.g., it is recommended that the board discuss the company’s activities to ensure a
diversity strategy relevant to the company and the organizational structure.
Add-on to the guidelines in regard to the preparation of an action plan in order to reduce Co2 footprint.
Removal of recommendations regarding the establishment of a whistleblower scheme, as this is now regulated via the legislation in force from January 1, 2021. However, an element in terms of the establishment of a whistleblower portal has been added.
Increased focus on reporting, so that the private equity funds take on even greater responsibility
in regard to its portfolio companies reporting data on developments in financial performance to
Active Owners Denmark for the purpose of preparing an annual analysis and report on the
economic development of private equity-owned companies.

When the need arises, Active Owners Denmark will revise the guidelines. Historically, a revision has
been necessary every 2 to 3 years.

III. Guidelines applicable to private equity funds

This section presents the guidelines that apply at the level of private equity funds, while the
guidelines that apply to private equity-owned companies are presented in section 4. The
guidelines at the level of private equity funds include the following actors:

1. The management company that has an advisory agreement with the investment fund. The
management company is where the employees working on investments in the private equity fund
are typically employed.

2. The investment fund (usually established as a limited partnership) and its investors.

Other actors (not covered by the guidelines):

3. The private equity fund’s portfolio companies.
4. Active Owners Denmark.
5. The investors in the investment fund.
6. The employees in the portfolio companies
7. The management company’s industrial network.

The guidelines below aim to provide an overview of the private equity fund’s overall business.

1. The following should be published on the Danish private equity fund’s website:

Guidelines regarding the management company

1. We recommend that the private equity fund confirms that it fully complies with the Active
Owners Denmark guidelines at the fund level – either in the form of “comply or “explain”. Potential
deviations must be justified.
2. It is recommended that the private equity fund outline the history of the management company,
the number of investments funds under management, and the total sum of capital commitments in
the current investment funds.
3. We recommend that the private equity fund presents the management company’s team and
divides it into investment teams, risk management, administration, etc. If the company has a board
of directors, the names and positions of the members must be stated.
4. It is recommended that the private equity fund provides information on the management
company’s state under the AIFM legislation, including whether the company has:
a. Authorization – and fully covered by the AIFMD and supervision, or
b. Registration, and only covered by the AIFMD to some extent.
5. It is recommended that the private equity fund generally describes the management company’s
working methods in relation to acquisitions and development of companies.

6. We suggest that the private equity fund describes the management company’s investment
policies in relation to ethical matters and ESG. The description can be a reference to compliance
with the Global Compact, PRI, etc.

7. It is recommended that the private equity fund generally describes its climate policy and / or, if
applicable, an action plan to reduce CO2 footprint significantly within a short number of years.

8. It is recommended that the private equity fund defines the management company’s diversity
policies and / or diversity strategy, including initiatives and processes for achieving increased
diversity in all management layers at the Board of Directors and among employees.

9. Moreover, we suggest that the private equity funds appoint a person responsible for the press
and external communication and provide the name and contact information on its website.

10. It is recommended that the private equity fund make the financial statements of the
management company available on the company’s website.
Guidelines regarding the investment fund

11. We suggest that the investment criteria in the individual investment fund are listed on the
website, including:

a. Geographical focus areas
b. The size of companies preferred by the investment fund measured by Enterprise Value.

12. It is recommended that the names of the investors in the individual investment fund as well as
the percentage distribution of investors by type and country are listed on the website. This division
could advantageously be:

a. Danish pension companies
b. Other Danish financial investors
c. Danish Family Offices
d. Other Danish investors
e. Foreign financial investors
f. Other foreign investors

13. We suggest that the co-investment program (including Carried Interest) is described for the
individual investment fund if it deviates significantly from the market conformity.

14. It is recommended that the private equity fund provides information on whether the individual
investment fund is covered by the AIFMD and thus, among other things, has a depositary
attached.

15. It is recommended that the private equity fund make the annual financial statement of the
investment funds available on the company’s website or prepare a shirt annual statement on the
investments fund’s financial performance in the given year.
Matters concerning the private equity fund’s portfolio companies
16. We suggest that the private equity fund presents the individual investment fund’s portfolio
companies, stating:
a. Geographical location of the headquarter.
b. Industry (Industrial, service, technology, IT, retail, etc).
c. Responsible investment partner at the management company and a reference to the company’s
website.
d. A link to the portfolio company’s latest financial statement.

17. It is recommended that the private equity fund’s website provided an option for downloading
an annual report from the portfolio companies (possibly as a link to the portfolio company’s
website).

2. Reporting to Active Owners Denmark

Private equity funds want to support transparent reporting to external stakeholders. Among other
things, this means that the private equity fund is recommended to report data for an annual report
carried out by Active Owners Denmark on the development of the industry.
This includes data on:

Reporting on raised capital per. investment fund.
Reporting the investments fund’s preferences in regard to company size measured by Enterprise Value.

Furthermore, we suggest that the private equity fund support that all of its portfolio companies
report data on developments in financial performance to Active Owners Denmark with the preparation of the annual report on the economic development of private equity-owned companies in mind.

4. Communication standards in cases of acquisitions and sale of companies

Private equity funds want to communicate about buying and selling companies to all relevant
stakeholders, such as the company’s customers, employees, suppliers, the private equity fund’s
investors as well as to the press.
Private equity funds emphasize communicating openly about relevant matters to the relevant
stakeholders. They also draw attention to the fact that some matters concerning acquisitions and
exits may be subject to confidentiality and there cannot be communicated with the same extent of
transparency for reasons like e.g., the activities of the company and the owners.

5. The role and responsibilities of the private equity funds

Private equity funds usually want to work closely with experienced businesspeople in the work of
investing in and further developing companies. Private equity funds emphasize that the roles and
responsibilities between the funds and the advisors are clearly defined, so that there are no
impartiality issues in relation to the acquisition and sale of certain companies.

IV. Guidelines for good corporate governance in private equity-owned companies

1. Information in the annual report

Each member of the Board of Directors and the management is responsible for ensuring that the
annual report and other financial reporting is prepared in accordance with legislation, common
standards, and additional requirements for financial statements in the articles of association, etc.

The annual report and other financial reporting should be supplemented with additional financial
and non-financial information where it is considered necessary or relevant in relation to the
recipients’ information needs.

The management and Board of Directors are responsible for ensuring that the financial reporting
is understandable and balanced as well as provides a true overview of the company’s assets, liability, financial position, results, and cash flows. The management’s report must contain a
genuine view on the matter to which the report relates, including value creation and prospects.

When considering and approving the annual report, the Board of Directors must specifically decide
whether the financial reporting takes place on the assumption of continued operation (going
concern assumption), including any special assumptions on which is this I based. In addition, any
uncertainties in this relation.

1.1. We suggest that the management’s report states that the majority of the shares in the
company are owned by a private equity fund that is a member of Active Owners Denmark, and that
the company thereby is covered by the Active Owners Denmark guidelines.

1.2. It is recommended that the annual report includes a reference to the company’s website, where
the annual report is available as well.

1.3. It is recommended that the management report account for the special financial risks
associated with the chosen capital structure.

Note: When a private equity fund invests in a company, the price is usually financed with both
equity and dept. This means that the private equity fund works with leverage, which contains a
number of financial risks that the reader of the account should have adequate insight into. Active
Owners Denmark’s Private Equity Fund Committee believes that it creates the greatest extent of
transparency when the company explains any special circumstances associated with the chosen
capital structure.
1.4. It is recommended that the management report account for the development in the number of
employees during the year. The statement may advantageously contain a list of figures from the
beginning and end of the year divided by regions and countries.

Note: The development in the number of employees in private equity-owned companies is a
significant key figure in relation to societal contributions. Active Owners Denmark’s Private Equity
Committee thereby finds it relevant that the company discloses this development in the annual
report.

1.5. It is recommended that the management report disclose the following matters concerning the
Board of Directors and ownership:

1. The private equity fund that owns the company and with which ownership interest
2. Who the individual members of the Board of Directors are nominated by
3. The individual’s position
4. The individual’s other management positions, including positions on executive boards, boards of
directors and supervisory board, including management committees in Danish and foreign
companies as well as demanding organizational tasks
5. The direct shareholding of the Board of Directors and the Executive Board as total groups if it
exceeds 5% on balance sheet date.

Note: Participation in board and committee meetings promotes the necessary and constructive
debate, which is why information on member’s participation in board and committee meetings is
relevant. Physical participation should be the norm, but virtual participation is also considered
participation.

1.6. It is recommended that the management report disclose the company’s internal control and
risk management systems regarding business risks.

Note: The information on the company’s risk management regarding strategic and business risks
complements the statutory statement in the management’s review of the company’s internal
control and risk management systems in relation to the financial reporting process.

2. The Board of Directors’ tasks and responsibilities

It is the responsibility of the Board of Directors to look after the interests of the shareholder with
proper care and with due regard to the other stakeholders. It is the board’s task to take care of the
overall and strategic management of the company in order to ensure value creation. The Board of
Directors must agree upon the company’s strategic goals and ensure that the necessary
prerequisites for achieving these goals are present in terms of both financial and competence
resources, as well as ensure sound organization of the company’s activities.

The prerequisite for fulfilling the company’s strategic ends is that the Board of Directors employs
a competent Executive Board, determines the division of work between the Board of Directors
and the Executive Board, the Executive Board’s tasks and employment conditions and ensure clear
guidelines for accountability, planning, follow-up and risk management. It is the responsibility of
the Board of Directors to exercise control over the Executive Board and to present the way to
which this control is to be exercised.

It is the Board of Directors’ job to ensure that the Executive Board continues to be under
development, maintained or dismissed and that the Executive Board’s remuneration reflects both the long-term value creation in the firm and the results that the Executive Board achieves
otherwise. The Chairman organizes and convenes the meetings of the directors in order to ensure
the efficiency of the board’s work and create the best possible conditions for the members’ work
both individually and collectively. This also ensures that the individual member’s knowledge and
competencies are used in the best possible way and for the benefit of the company.

2.1. It is recommended that the Board of Directors annually review and approve guidelines for the
Executive Board, including establishing requirements for timely, reliable, and adequate reporting
to the Board of Directors.

Note: Guidelines on the division of labor between the Board of Directors and the Executive Board
should state the detailed circumstances for the interaction, including for example disposition rules
and division of responsibilities between the member of the Executive Board. If the Board of
Directors or the Executive Board has special wishes regarding work procedures, approval of
policies and authorizations, this should be stated in the guidelines.

2.2. It is recommended that the Board of Directors adopt policies for the company’s social
responsibility.

Note: In this regard, the Board of Directors may decide on the company’s possible adherence to
national and international voluntary Initiatives.

2.3 It is recommended that the Board of Directors annually discuss the company’s activities to
ensure diverse management with relevance to the specific company and to prepare and adopt a
policy for diversity. The policy should be published on the company’s website.

Note: Diversity includes i.s. age, international experience, and gender. A diversity policy should
address the issues relevant to the company in relation to diversity. This promotes a relevant
degree of diversity, strengthens the management’s qualifications and competencies, and which
takes the future development of the company into account.

3. Management Committee

Management committees can contribute to increasing efficiency and the quality of the board
work. Management committees are committees set up by the board of directors. The
establishment of a management committee only has a preparatory purpose prior to the
consideration by the Board of Directors. Significant Information, that every member needs to be aware of, cannot only be presented to the Management Committee, and necessary consideration
by the Board of Directors cannot be limited or omitted.

The Board of Directors retains full responsibility for all the decisions prepared in a management
committee.

The Board of Directors should consider whether the company is specifically exposed, or whether
there are other factors that motivate the establishment of permanent committees. This can help
to achieve better utilization of the special competencies among board members, for example
audit, nomination and remuneration committees, R&D, or risk committees.

The Board of Directors could also set up ad hoc committees in relation to issues of a significant
but temporary nature. This can help to ensure the necessary focus on the task in question as well
as a timely prioritization of this. Such issues may be, for example, ESG matters, ethics or Imagerelated issues, major acquisitions, or attempts. The recommendations do not include ad hod
committees.

3.1. In cases of the Board of Directors establishing an audit committee, it is recommended that the
composition of the audit committee ensures that the committee has such expertise and
experience that it holds an updated understanding of financial matters as well as accounting and
auditing matters in similar companies.

Note: As a rule, the audit committee should consist of board members and not external parties, as
these may not have the same understanding of the company’s affairs and are not necessarily
subject to the same responsibilities as board members.

3.2 It is recommended that the audit committee, prior to the approval of the annual report and
other financial reports, monitor and report to the supreme governing body on:

1. Accounting policies on key areas
2. Significant accounting estimates
3. Transactions with related parties
4. Uncertainties and risks in relation to expectations
5. Going concerns
3.4. We suggest that the audit committee:

1. Addresses the company’s risk management processes
2. Annually assess the need for an internal audit or extended controller function
3. Monitors the Executive Board’s follow-up on the potential internal audits etc., conclusions, and
recommendations.

Note: If it is decided to establish an internal audit, the board may choose to outsource the task.
The person in question handles the internl audit with reference to the board of directors or the
audit committee.

4. Risk management and internal control

Efficient risk management and an effective internal control system helps to reduce strategic and
business risk in order to ensure compliance with applicable rules and regulations, and to ensure the
quality of the basis for management decisions and financial reporting. It Is essential that risks are
identified and that risks are managed in an appropriate manner.

Effective risk management and internal control are a prerequisite for the Board of Directors and
the Executive Board to be able to carry out tasks. It is therefore essential that the Board ensures
that there is effective risk management and effective internal controls. An Independent and
competent audit is crucial for the Board’s work.

4.1. It is recommended that the management and the Board of Directors at least once a year
identify the most significant business risks associated with the realization of the company’s
strategy and vision as well as risks related to financial reporting.

Note: This evaluation can advantageously be integrated into the Board of Directors’ general
evaluation.

4.2. It is recommended that the Executive Board regularly reports to the Board of Directors on
developments within the significant risk areas and compliance with the adopted policies, etc. with
the Intention of the board being able to follow developments and make the necessary decisions.

4.3. It is recommended that the Board of Directors decide to establish a combination of policies
and guidelines regarding a whistleblower portal as well as set up for further processing of reports
in order to facilitate appropriate and confidential reporting of genuine suspicions.

Note: The reporting from a whistleblower scheme should be anchored in the Board and if possible,
through an Audit Committee.

V. Reporting from Active Owners Denmark

In order to create a better understanding of private equity funds and their work, it is important that
the industry takes responsibility for collecting and consolidating data. This data must come both
from portfolio companies and from the funds themselves. Annually, Active Owners Denmark
presents a status of compliance and includes this conclusion in the Annual Report on Industry
Activity or in a similar reporting format. The report includes an overview of trends ad development
within the industry.

Appendix A – Funds covered by the Active Owners Denmark’s guidelines

Covered by the guidelines:
Axcel
Capidea
CataCap
Gro Capital
Maj Invest
BWB Partners
Polaris
VIA Equity

Partly covered by the guidelines:
Adelis Equity Partners
Advent International Plc
Altor Equity Partners
CVC Capital Partners
EQT
FSN Capital Partners
Goldman Sachs
IK Investment Partners
Nordic Capital
Silverfleet
Triton
Verdane
Waterland private Equity

Not covered by the guidelines:
A.P. Møller Capital
Copenhagen Infrastructure Partners
Jysk-Fynsk Kapital
Vækst-Invest Nordjylland
VækstPartner Kapital