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SpareBank 1 Sørøst-Norge

Environmental & Social Information Dec 13, 2021

3753_rns_2021-12-13_b5500ece-2a76-4777-8799-0d7f8abaf52c.pdf

Environmental & Social Information

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SpareBank 1 Sørøst-Norge Green Bond Second Opinion

December 10, 2021

SpareBank 1 Sørøst-Norge is a Norwegian local savings bank, established in June 2021 as the result of a merger between SpareBank 1 Buskerud-Vestfold and SpareBank 1 Telemark. The bank is part of the SpareBank 1 alliance, the second largest financial institution in Norway. SpareBank 1 Sørøst-Norge's largest lending exposure is to the real estate segment, but the bank also provides loans to local industrial activities, agriculture, forestry, transport, and energy.

Under this framework, green buildings are expected to receive 85% of the proceeds, and the remaining is to be split between district heating and cooling, sustainable manufacturing technology and renewable energy. The issuer expects a 50/50 split between refinancing and new finance. New buildings (from 2021 onwards) need an energy performance 10% better than regulation. Buildings built from 2012 to 2020 are eligible without further criteria than construction year. Older buildings need an Energy Performance Certificate (EPC) A or B or be BREEAM Excellent. Shopping malls, airport buildings and cabins will however be excluded. Direct financing of fossil fuel solutions is excluded in all categories.

CICERO Green assesses that SpareBank 1 Sørøst-Norge is likely aligned with the EU-taxonomy mitigation thresholds and most Do No Significant harm (DNSH) criteria. The consultancy Multiconsult has on behalf of the bank, assessed the top 15% of existing building stock. The approach raises some concerns. Regarding new buildings, investors should be aware that NZEB is not established in Norway and that regulations on energy efficiency for new buildings have not been tightened since 2016. The bank is likely partly aligned to the criteria related to Sustainable use of water and Pollution prevention and control for construction and renovation of buildings. SpareBank 1 Sørøst-Norge conducts thorough ESG-assessments that are included in the credit process, including physical and transitional climate risk, environment and human and workers' rights. CICERO Green assesses that Sparebank 1 Sørøst-Norge seems to fulfil the minimum social safeguards of the EU Taxonomy. The project category "sustainable manufacturing and technology" is too broad to assess alignment with the EU Taxonomy activities.

SpareBank 1 Sørøst-Norge has strong sustainability policies and emissions reduction targets that aim to be aligned with the Paris Agreement, both for its internal operations and its portfolio. The bank has implemented the TCFDguidelines and is working systematically with climate risk and adaptation. Among others, the bank identifies the properties most exposed to climate risks and plans to offer favourable loan terms on adaptation measures. The bank has a strong consensus-based selection process including life cycle analysis, supply chain and lock in considerations, and a high focus on sustainability training of the client advisors. Impact reporting will be externally verified, but we see a risk of overestimating impacts from the green buildings category.

Based on the overall assessment of the projects that will be financed under this framework, and governance and transparency considerations, SpareBank 1 Sørøst-Norge's green bond framework receives a CICERO Light Green shading and a governance score of Excellent. In order to achieve a darker green shading, the framework would need stronger eligibility criteria in the Green buildings category.

SHADES OF GREEN

Based on our review, we rate the SpareBank 1 Sørøst-Norge's green bond framework CICERO Light Green.

Included in the overall shading is an assessment of the governance structure of the green bond framework. CICERO Shades of Green finds the governance procedures in SpareBank 1 Sørøst-Norge's framework to be Excellent.

GREEN BOND PRINCIPLES

Based on this review, this Framework is found in alignment with the principles.

1 Terms and methodology _____________3
Expressing concerns with 'Shades of Green'3
2 Brief description of SpareBank 1 Sørøst-Norge's green bond framework and related policies ____4
Environmental Strategies and Policies4
Use of proceeds6
Selection6
Management of proceeds 7
Reporting7
3 Assessment of SpareBank 1 Sørøst-Norge's green bond framework and policies ________9
Overall shading9
Eligible projects under the SpareBank 1 Sørøst-Norge's green bond framework9
Background 12
EU Taxonomy13
Governance Assessment15
Strengths 15
Weaknesses 16
Pitfalls16
Appendix 1: Referenced Documents List _________18
Appendix 2: EU Taxonomy criteria and alignment ________19
Electricity generation using solar photovoltaic technology 19
Electricity generation from wind power 22
Electricity generation from hydropower24
District heating/cooling distribution28
Construction of new buildings 31
Renovation of existing buildings36
Acquisition and ownership of buildings 38
Appendix 3: About CICERO Shades of Green____________40

1 Terms and methodology

This note provides CICERO Shades of Green's (CICERO Green) second opinion of the client's framework dated December 2021. This second opinion remains relevant to all green bonds and/or loans issued under this framework for the duration of three years from publication of this second opinion, as long as the framework remains unchanged. Any amendments or updates to the framework require a revised second opinion. CICERO Green encourages the client to make this second opinion publicly available. If any part of the second opinion is quoted, the full report must be made available.

The second opinion is based on a review of the framework and documentation of the client's policies and processes, as well as information gathered during meetings, teleconferences and email correspondence.

Expressing concerns with 'Shades of Green'

CICERO Green second opinions are graded dark green, medium green or light green, reflecting a broad, qualitative review of the climate and environmental risks and ambitions. The shading methodology aims to provide transparency to investors that seek to understand and act upon potential exposure to climate risks and impacts. Investments in all shades of green projects are necessary in order to successfully implement the ambition of the Paris agreement. The shades are intended to communicate the following:

Sound governance and transparency processes facilitate delivery of the client's climate and environmental ambitions laid out in the framework. Hence, key governance aspects that can influence the implementation of the green bond are carefully considered and reflected in the overall shading. CICERO Green considers four factors in its review of the client's governance processes: 1) the policies and goals of relevance to the green bond framework; 2) the selection process used to identify and approve eligible projects under the framework, 3) the management of proceeds and 4) the reporting on the projects to investors. Based on these factors, we assign an overall governance grade: Fair, Good or Excellent. Please note this is not a substitute for a full evaluation of the governance of the issuing institution, and does not cover, e.g., corruption.

2 Brief description of SpareBank 1 Sørøst-Norge's green bond framework and related policies

SpareBank 1 Sørøst-Norge is a local savings bank, established in June 2021 as the result of a merger between SpareBank 1 BV and SpareBank 1 Telemark. The new bank is continuing the sustainability focus of its predecessors, and sustainability is an integral part of SpareBank 1 Sørøst-Norge's business strategy. The new bank is a part of the SpareBank 1 alliance, the second largest financial institution in Norway. Through its alliance and its main subsidiaries EiendomsMegler 1 BV, EiendomsMegler 1 Telemark AS, Z-Eiendom AS and SpareBank 1 Regnskapshuset BV AS, the bank provides its 140,000 clients with solutions within finance, savings, insurance, and payments. The bank's largest lending exposure is to the real estate segment, but the bank is also providing loans to other sectors like local industrial activities, the agricultural sector, forestry, transport, and energy. Sparebank 1 Sørøst-Norge has 70% retail and 30% corporate customers.

The bank has 17 branch offices across the Viken and Vestfold and Telemark counties and has as of mid-2021 NOK 100 billion in business capital. The bank aims to double its green exposures to 25 billion NOK by 2025.

Environmental Strategies and Policies

SpareBank 1 Sørøst-Norge's sustainability strategy consists of three main pillars:

    1. Move beyond compliance in the fight against financial crime (Responsible);
    1. substantially ramp up our internal competence building on sustainability, and cooperate with the bank's owner foundations to share sustainability knowledge with customers and society at large (Dedicated)
    1. double the bank's green exposures to 25 bn NOK by 2025, and become the customer's sparring partner and advisor on sustainability issues (Carbon-conscious)
    1. To be offensive on climate related issues, and assist the bank's customers to do the same.

SpareBank 1 Sørøst-Norge's largest environmental and climate impact is through its lending portfolio, and the bank has established a target to reduce the greenhouse gas (GHG) emissions per unit of value creation from the loan portfolio by 7.6 % annually from 2019 as a step-wise approach to reach net zero. The target is based on a UNEP assessment on what is needed in annual global reductions to achieve the 1.5ºC target by 20501 . Reductions can also be achieved through the purchase of high-quality (Gold Standard) carbon credits or if possible to invest corresponding amounts locally to reduce GHG-emissions. However, the issuer informs that offsets can only be applied to cover for the residual to the extent the bank does not reach the target.

SpareBank 1 Sørøst-Norge is certified according to the new banking and financial criteria under the Eco-Lighthouse certification scheme, and uses this to work systematically with waste management, energy use, purchasing and transport for its internal operations. All branch offices were Eco-Lighthouse certified in line with the new banking and finance criteria in 2020. The bank has the same climate target for its internal operations as for its loan portfolio. To reach this target, the bank has established internal environmental targets for the period 2021-23 (most likely to be extended to 2025) related to increased share of zero-emission transport (from 17% to 30%), increased share of recycled waste (from 65% to 75%), reduce the average energy consumption (from 200

&#sessed and their strengths and weaknesses are discussed in this section. The strengths of an investment framework with respect to environmental impact are areas where it clearly supports low-carbon projects; weaknesses are typically areas that are unclear or too general. Pitfalls are also raised in this section to note areas where SpareBank 1 Sørøst-Norge should be aware of potential macro-level impacts of investment projects.

x27;Second Opinion' on SpareBank 1 Sørøst-Norge's Green Bond Framework 1ths of an investment framework with respect to environmental impact are areas where it clearly supports low-carbon projects; weaknesses are typically areas that are unclear or too general. Pitfalls are also raised in this section to note areas where SpareBank 1 Sørøst-Norge should be aware of potential macro-level impacts of investment projects.

Cut global emissions by 7.6 percent every year for next decade to meet 1.5°C Paris target - UN report (unep.org)

kWh/m2 to 175 kWh/m2), to change to purchase guarantees of origin for renewable energy and to work to increase the share of environmentally certified suppliers (from 86 to 90).

SpareBank 1 BV and SpareBank 1 Telemark reported on Scope 1, 2 and 3 for 2020, and saw a reduction of around 30% from 2019. Scope 3 emissions calculated represent around 1/3 of the total emissions, and the main sources included are business travel and waste handling and do not include emissions in the bank's portfolio. However, portfolio emissions are accounted for in the bank's annual report, and for 2021 both emissions from the personaland the corporate market will be included. The main reason for the emission reduction was less demand for transport and business travel due to travel restrictions because of Covid-19, and less waste, electricity consumption and district heating use due to mandatory use of home office.

The bank is reporting according to the TCFD guidelines and both transitional and physical climate risks have been assessed using scenarios developed by NGFS2 . Furthermore, the bank has started the assessment of climate risks on an asset basis. The bank has estimated the carbon emissions of its loan portfolio, as well as the emissions intensity per NOK millions of lending, and finds that the carbon emissions intensity is greatest in the industry and transport segments. The loan portfolio is considered by the bank to have a relatively small carbon footprint, and the bank does not have direct loan exposure to fossil energy production. The TCFD-assessment further concludes that the bank is exposed to medium- and long-term physical climate risks, particularly within the property sector related to commercial properties or homes located in places at increased risk of flooding due to rain, landslides or storm surges. Regarding adaptation, the bank has identified geographical areas where adaptation measures may be needed, and will approach clients identified with high climate risk and offer favorable loan terms on adaptive measures. The bank increases the credit terms for clients not accepting the offers for adaptive measures or that cannot demonstrate that adaptive measures are taken.

SpareBank 1 Sørøst-Norge also sees increased business opportunities in the green transition, e.g. in offering green products like green loans, among others within the real estate sector. The bank aims at working with its customers to incentivize sustainable choices and thereby reducing emissions. One example is to encourage renovation of buildings instead of demolition and new construction.

All lending activities in SpareBank 1 Sørøst-Norge must go through the bank's regular credit approval processes. The bank conducts ESG-assessments for all new corporate loans (from 2021) using a dedicated sustainability module integrated in the loan processing system. It reviews a broad set of ESG risks in assessing such loans: a) know your customer governance, physical and transitional climate risk, environmental risks such as pollution and waste, energy efficiency (EPC-labelling), environmental certifications, human and workers' rights and economic crime. Where high ESG-risks are identified, credit decisions are taken to a higher managerial level and the bank's sustainability team is consulted. This has resulted in certain activities being rejected. Examples are thermal coal, tar sand, projects than can increase water shortage in dry areas and environmental misconduct. ESG-requirements are also set through the bank's credit policy and in guidelines for fund management. The bank has a sustainability policy confirming alignment to the guidelines listed in the minimum social safeguards of the EU taxonomy and states that the bank respects human rights and does not contribute to violations of these. All the bank's staff received basic sustainability training in 2020. Going forward training will be strengthened and tied to competence goals forming part of the bank's scorecard system.

The SpareBank 1 alliance has conducted risk assessments of their suppliers to identify suppliers with a risk of having a negative impact on e.g. environment and on labour and human rights. The assessment has resulted in increased scrutiny and follow up of suppliers identified of having a risk of negative ESG-impacts. The bank has established a Code of Conduct also valid for suppliers, requiring alignment to relevant legal frameworks and guidelines with regard to environment, climate change, human and labour rights, and corruption. To ensure

| For buildings larger than 5.000m2
2ngs larger than 5.000m2
Network for Greening the Financial System, https://www.ngfs.net/en

'Second Opinion' on SpareBank 1 Sørøst-Norge's Green Bond Framework

implementation, the CoC is attached to contracts. Furthermore, the bank has internal and external whistleblowing channels to anonymously report concerns, and is requiring reporting on alignment to the ESG-requirements.

The bank is issuing a joint sustainability and financial report conducted in line with the Global Reporting Initiative (GRI). Furthermore, SpareBank 1 Sørøst-Norge has committed to:

  • The Roadmap for Green Competitiveness in the Norwegian Financial Sector, aiming to achieve the targets in the roadmap in this strategy period (2021-2023).
  • The UN Principles for Responsible banking (in 2019).
  • The UN Sustainable Development Goals.
  • - The UN Global Compact, OECD Guidelines for Multinational Enterprises, the UN Guiding Principles for Business and Human Rights, including minimum labor rights outlined in the ILO Conventions.

Use of proceeds

Eligible assets under the green bond framework will be used to finance a portfolio of loans that promote the transition towards low-carbon and climate-resilient development (the green loan portfolio) within the categories green buildings, district heating and cooling, sustainable manufacturing technology and renewable energy.

Green bond net proceeds can be used to re-finance and finance loans, and the bank expect a 50/50 split between re-finance and finance. Only loans that comply with the list of eligible green loans as given in table 1 below are deemed eligible to be financed by green bonds.

The bank is excluding investments linked to fossil energy generation, nuclear energy generation, research and/or development within weapons and defense, potentially environmentally negative resource extraction, gambling, pornography or tobacco, nor other activities in violation of the bank's established sector guidance.

Selection

The selection process is a key governance factor to consider in CICERO Green's assessment. CICERO Green typically looks at how climate and environmental considerations are considered when evaluating whether projects can qualify for green finance funding. The broader the project categories, the more importance CICERO Green places on the governance process.

SpareBank 1 Sørøst-Norge has established a green bond committee (GBC) that will be responsible for the green bond framework and for the evaluation and selection of loans to be included in the green loan portfolio. The GBC consists of members from the bank's credit management, sustainability and treasury teams. All decisions will be made by consensus, and the Head of Sustainability holds a veto.

To qualify as a green loan that can be financed using green bonds, the loan must meet the eligibility criteria defined in the Use of Proceeds section of the bank's green bond framework. Relevant business units in SpareBank 1 Sørøst-Norge, like representatives from corporate and retail banking segments, can nominate loans for inclusion in the green loan portfolio. The GBC will keep a register of the portfolio of identified green loans.

Life-cycle, supply chain, and lock-in effects are considered as part of the selection criteria for new loans, e.g. related to the exclusion of activities that are not sustainable over the long term, like fossil fuel and emission intensive activities, and in the assessment of new loans for commercial real estate projects, through questions related to material use, recycling and reuse, and (location-related) physical climate risk and nature risk. Furthermore, the GBC holds the right to exclude any green loans already funded by green bonds. If a green loan already included in the green loan portfolio no longer meets the criteria in the green bond framework it will be removed from the green loan portfolio. Removal of loans from the green portfolio will be done if mistakes are

'Second Opinion' on SpareBank 1 Sørøst-Norge's Green Bond Framework

discovered, or if the bank receives information or otherwise discovers that a loan is not meeting the criteria as expected.

To ensure traceability, all decisions made by the GBC will be documented and filed. The GBC is also in charge of potential future oversight and updates of the green bond framework. Potential future updates of the green bond framework will not impact the green bonds issued under this version of the framework.

Management of proceeds

CICERO Green finds the management of proceeds of SpareBank 1 Sørøst-Norge to be in accordance with the Green Bond Principles. An amount equal to the net proceeds from issued green bonds will be allocated towards the financing and refinancing of the bank's green loan portfolio.

SpareBank 1 Sørøst-Norge will strive to achieve a level of allocation to ensure that the value of the green loan portfolio at all times exceeds the total nominal amount of green bonds outstanding. Proceeds will be allocated prorata across the green loan categories based on the size each category represents. Green loans will be tagged for easy tracking. Net proceeds from green bonds awaiting allocation to the green loans portfolio will be managed according to the regular liquidity management policy of the bank's Treasury department. The exclusions listed in the Use of Proceeds above will also apply for temporary holdings of net proceeds.

The volume of green loans will be significantly higher than the proceeds from the green bonds, hence there will be a robust buffer to comply with the requirement that the value of green loans always exceeds proceeds.

Reporting

Transparency, reporting, and verification of impacts are key to enable investors to follow the implementation of green finance programs. Procedures for reporting and disclosure of green finance investments are also vital to build confidence that green finance is contributing towards a sustainable and climate-friendly future, both among investors and in society.

SpareBank 1 Sørøst-Norge will issue a green bond report that will be made available on the bank's website. The report will include an allocation and an impact report and will be published annually as long as there are green bonds outstanding or until full allocation.

Allocation reporting will provide information on the size of the identified green loan portfolio and each green loan category, nominal amount of green bonds outstanding, the share of the green loan portfolio currently financed by green bonds and the amount of net proceeds awaiting allocation (if any). The bank will provide an external review of the allocation reporting that will be made available on the bank's website.

Impact reporting. The impact report aims to disclose the environmental impact of the green loans financed by green bonds, and will be aggregated for each green loan category and be made on a best intention basis. The impact assessment may, where applicable, be based on the metrics listed below.

Green Buildings

• Estimated annual energy consumption (kWh/m2 ) and annual GHG emissions (tCO2e) compared to baseline

District Heating and Cooling

• Financed energy generation capacity and estimated annual GHG emissions (tCO2e) compared to baseline

Manufacturing and Technology

• Examples of individual loans/activities included in the green loan portfolio including indication of their environmental impact

Renewable Energy

• Financed energy generation capacity and estimated annual avoidance of GHG emissions (tCO2e)

Grid factors and methodologies used for calculation of impacts will be disclosed. Impact reporting will be conducted by a third party, in close cooperation with the bank's sustainability and finance departments. Results will be externally verified.

3 Assessment of SpareBank 1 Sørøst-Norge's green bond framework and policies

The framework and procedures for SpareBank 1 Sørøst-Norge's green bond investments are assessed and their strengths and weaknesses are discussed in this section. The strengths of an investment framework with respect to environmental impact are areas where it clearly supports low-carbon projects; weaknesses are typically areas that are unclear or too general. Pitfalls are also raised in this section to note areas where SpareBank 1 Sørøst-Norge should be aware of potential macro-level impacts of investment projects.

Overall shading

Based on the project category shadings detailed below, and consideration of environmental ambitions and governance structure reflected in SpareBank 1 Sørøst-Norge's green bond framework, we rate the framework CICERO Light Green.

Eligible projects under the SpareBank 1 Sørøst-Norge's green bond framework

At the basic level, the selection of eligible project categories is the primary mechanism to ensure that projects deliver environmental benefits. Through selection of project categories with clear environmental benefits, green bonds aim to provide investors with certainty that their investments deliver environmental returns as well as financial returns. The Green Bonds Principles (GBP) state that the "overall environmental profile" of a project should be assessed and that the selection process should be "well defined".

Category Eligible project types Green Shading and some concerns
Green
buildings
Loans financing the acquisition, ownership,
construction, and renovation of residential,
commercial, and public buildings meeting the
following criteria:
Light Green

The majority of the green bond proceeds
(85%) is expected to be allocated to green
buildings and remaining equally spread
between the other three categories.
Buildings built in 2021 or later

Buildings with an energy consumption that is
10% lower than national minimum
requirements (TEK17), or

Buildings with BREEAM-NOR 3.03 Excellent
certificate.

Within the Green buildings category, the
bank estimates that 10-15% will be
buildings built in 2021 or later, and 70-
80% will be buildings built between 2012-
2021. For building built before 2021 the
expected share of BREEAM-certified
buildings is 0-5%.
For buildings larger than 5.000m2
:
(i)
upon completion having undergone
testing for air-tightness and thermal
integrity (unless robust and traceable
quality control processes are in place
during construction), and

An energy consumption 10% lower than
national minimum requirements and testing
of air-tightness and calculation of the
Global Warming Potential are in line with
the EU Taxonomy.

SpareBank 1 Sørøst-Norge confirms that to
be eligible buildings also need to have an
energy consumption 10% lower than

3 Expected to be in effect from 1st quarter 2022.

'Second Opinion' on SpareBank 1 Sørøst-Norge's Green Bond Framework

(ii) calculation of the Global Warming Potential for each stage of the life cycle.

Buildings built before 2021

  • Energy Performance Certificate A, or
  • Buildings within the top 15% of the national or regional stock in terms of primary energy demand, defined as
  • buildings built according to Norwegian building codes of 2010 (TEK10) or 2017 (TEK17) (to ensure TEK10-alignment, we use a conservative 2-year time lag and include buildings built from 2012 and onwards, for hotels and restaurants we use a 3-year time lag), or
  • for buildings built prior to 2012, Energy Performance Certificate B, or
  • Commercial buildings with BREEAM-NOR Excellent certificate or better, and minimum 6 credits in the BREEAM-NOR "Energy" category4 .

For large, non-residential buildings (with an effective rated output for heating systems, systems for combined space heating and ventilation, air-conditioning systems or systems for combined air-conditioning and ventilation of over 290 kW) it is efficiently operated through energy performance monitoring and assessment.

Renovated buildings

  • Costs related to renovations leading to a reduction in primary energy demand of at least 30%.
  • For the full building to qualify, it should after renovations be expected to meet the criteria above for buildings built either before or after 2021.

Residential buildings used for leisure (cabins) are excluded. Buildings used for the exploration, extraction, refining and distribution of fossil fuels as well as other industry-specific buildings of emission intensive industries are excluded. Furthermore, shopping malls and airport buildings, with associated parking lots, are also excluded.

NZEB as soon as this is officially determined.

  • According to the bank, BREEAM-NOR 3.0 will be aligned with the EU Taxonomy.5
  • The BREEAM-NOR Excellent criteria reflect a high environmental standard, and combined with a minimum energy score, this will ensure a low climate impact. Depending on the type of building, EPC B could be given to buildings with an energy performance that is in line or even below current regulations. EPC-labels are valid for 10 years, so some buildings with old labels may have energy performance weaker than current regulation.
  • Shopping malls, airport buildings, industry-specific buildings of emission intensive industries and buildings heated directly with fossil fuels as well as cabins will be excluded from obtaining green loans.
  • Investors should however be aware that except from the exclusions given above, all commercial and residential buildings built between 2012 and 2020 in line with the building regulations qualify under the framework.
  • Through the ESG-assessments the bank identifies the properties most exposed to physical climate risk and offer adaptation solutions where needed. The bank increases the credit terms for clients not accepting the offers for adaptive measures or that cannot demonstrate that adaptation measures are taken. The bank further informs us that they aim to ensure that properties improve the climate resilience during renovations.

Access to public transportation is not a screening criterion to receive green loans.

Renovation of existing buildings is key to succeed in the transition to a low carbon future, as they have a considerably lower carbon footprint that the construction of new buildings.

4 https://www.breeam.com/BREEAMIntNDR2016SchemeDocument/content/06\_energy/ene01\_nc.htm

5 Nyheter – Grønn byggallianse (byggalliansen.no)

'Second Opinion' on SpareBank 1 Sørøst-Norge's Green Bond Framework

District
heating and
cooling
Loans financing the acquisition, construction,
development, operation, maintenance, and
improvement of facilities and related
infrastructure for district heating and cooling
where at least 95% of the fuel comes from
renewable sources such as locally supplied
forestry waste and residues, recycled wood waste,
or waste heat from nearby industries.


Medium to Dark Green
According to the bank, the selection
criteria ensure locally supplied materials,
where Norwegian standards and
regulations apply, ensuring sustainable
sourcing.
According to the bank district
heating/cooling using fossil fuels are
excluded, but the remaining 5% of fuels
may be from waste that include plastics.
The approximate size of the facilities is 1-6
MW.
Sustainable
manufacturing
and
technology
Loans financing manufacturing or industrial
facilities, processes or technologies ensuring one
or several of the following objectives:

Increasing prevention, collection, sorting,
recovery, and recycling of waste

Replacing fossil-based energy sources with
low-carbon alternatives

Reducing energy consumption by at least
30%

Reducing water consumption by at least 30%

Significantly reducing GHG emissions by at
least 30%

Developing circular economy adapted
products, production technologies and
processes

Increasing resilience against the effects of
climate change
All loans in this Green Loan category will be
subject to an individual due diligence and
approval process conducted by the Green Bond
Committee, evaluating the expected
environmental impact on a case by case basis.
Activities in this category relate to the following
categories in ICMA's Green Bond Principles:

Energy efficiency

Pollution prevention and control

Sustainable water and waste-water
management

Circular economy adapted products,
production technologies and processes, and/or
certified eco-efficient products

Climate change adaptation


Medium Green
Improving the resource and material
efficiency in industrial processes is
according to the IEA crucial for the green
transition. The project category is however
very broad, and the selection process
therefore becomes very important. There is
a risk that projects could be financed that
are part of an emission intensive supply
chain. The issuer is therefore encouraged
to screen for improvements that in a longer
perspective do not lock-in obsolete
technologies.
Examples of projects are within circular
economy, pollution prevention and
adaptation.
Waste-to-energy cannot be supported, only
investments related to the use of waste heat
for district heating pumps. Be aware that
waste heat could come from industries with
large emissions. Emission intensive
production or machinery, or machinery
powered by fossil fuels will be excluded.

Renewable energy Loans financing the acquisition, installation, construction, development, operation, maintenance, and improvement of:

Renewable energy

  • Renewable energy plants and installations, as well as manufacturing of relating technologies and equipment, within the following renewable energy categories:
  • Wind power
  • Solar power
  • Hydropower with a power density above 5W/m2 , or life-cycle emissions below 100g CO2e/kWh, or run-of-river plants without artificial reservoirs

Related infrastructure

• Smart grid solutions, smart meters, and other monitoring systems aimed at enabling reduction of energy consumption.

Loans may be for specific assets and projects or to companies with ≥90% of their revenues from activities aligned with defined criteria.

Activities in this category also relate to the Energy Efficiency category in ICMA's Green Bond Principles.

Dark Green

  • Renewable energy is key to a low carbon transition.
  • Large-scale renewable energy and construction project can have adverse local environmental impacts (for example on wildlife, ecosystems and biodiversity) and impacts on local communities.
  • Both onshore and offshore wind as well as stand-alone solar power projects will qualify, subject to a screening for not being in a contentious area with local opposition. The bank informs that there will be a dialogue with the developer on how to minimize visual impacts and impact on biodiversity from landscape changes from the construction phase.
  • If roof-based solar PV is funded, only the PV components, and not the whole building will be eligible.
  • New hydropower developments can be funded, as long as the DNSH-criteria are met, and the development is not in a contentious area with local opposition.
  • Power grids will not be financed.

Table 1. Eligible project categories

Background

Financing institutions and banks are vital driving forces to reach the Paris Agreement and can provide leadership through providing financing of activities necessary to reduce greenhouse gas emissions and adapt to a changing climate. Banks also have a significant role in managing climate risks. Having climate goals for the bank's operations and portfolio, including science-based targets, implementation of TCFD reporting and climate risk assessment of their customers in the ESG due diligence, represents best practices of the sector.

In February 2020, Norway released updated targets for 2030 to cut emissions by 50-55% from 1990 levels6 , and in 2021 adopted a climate plan outlining the policies to be implemented to reach the target7 . This document covers targets from the energy, land use, industrial processes and product use, agriculture, land-use change and forestry, and waste sectors. Greenhouse gas emissions have slightly decreased in Norway since 2015, but 2020 emissions were less than 4% lower than 1990 levels. Fast action is needed to reach the new 2030 goal.

6 https://www.regjeringen.no/no/aktuelt/norge-forsterker-klimamalet-for-2030-til-minst-50-prosent-og-opp-mot-55 prosent/id2689679/

7 Meld. St. 13 (2020–2021) - regjeringen.no

'Second Opinion' on SpareBank 1 Sørøst-Norge's Green Bond Framework

Construction and real estate currently stand for around 16% of the greenhouse gas emissions in Norway, when taking into account both direct and indirect emissions, and 40% of the country's energy consumption8 . According to the government's climate plan, measures to further increase energy efficiency must we weighed against the life cycle impacts of the building materials. The energy efficiency of buildings is dependent on multiple factors including increasing affluence and expectations of larger living areas, growth in population and unpredictability of weather, and greater appliance ownership and use9 .

Renewable energy use increased 3% in 2020 as demand for all other fuels declined. The primary driver was an almost 7% growth in electricity generation from renewable sources. Accordingly, the share of renewables in global electricity generation jumped to 29% in 2020, up from 27% in 2019. Globally, solar PV electricity generation is expected to increase by 145 TWh, almost 18%, to approach 1 000 TWh in 2021. Increases in electricity generation from all renewable sources should push the share of renewables in the electricity generation mix to an all-time high of 30% in 202110. In IEA's pathway to net zero, almost 90% of global electricity generation in 2050 comes from renewable sources, with solar PV and wind together accounting for nearly 70%. Annual clean energy investment worldwide will need to more than triple by 2030 to around \$4 trillion11.

According to the IEA, achieving net-zero emission targets depends on strong and targeted R&D and innovation efforts in critical technologies and industries. In the Sustainable Development Scenario, almost 35% of the cumulative CO2 emissions reductions by 2070 compared with the Stated Policies Scenario come from technologies that are currently at the prototype or demonstration phase which will not become available at scale without further R&D. About 40% of the cumulative emissions reductions rely on technologies that have not yet been commercially deployed in mass-market applications12.

EU Taxonomy

The EU Taxonomy, first introduced in 2020, seeks to set out common classification systems to determine the environmental sustainability of activities. The EU-taxonomy regulation13 defines six environmental objectives. To be considered environmentally sustainable, an activity must substantially contribute to one or more of the six objectives, not significantly harm any of the other six objectives (Do-No-Significant-Harm - DNSH) and comply with the technical screening criteria (TSC). In June 2021, EU published its delegated acts outlining the TSC for the climate adaptation and mitigation objectives, respectively, which it was tasked to develop after the Taxonomy Regulation entered into law in July 2020 (the Annex 1). 14 The delegated act also includes compliance with certain minimum social safeguards15, were we take the sectoral, regional and judicial context into account and focus on the risks likely to be the most material social risks.

CICERO Green has assessed eligible projects in SpareBank 1 Sørøst-Norge's green bond framework against the mitigation thresholds and the DNSH criteria for relevant activities in the Annex 1, as well as alignment with the minimum social safeguards. To qualify projects under the EU Taxonomy, the bank has to ensure that their clients align with the relevant criteria for the different activities. Criteria, activities with NACE-codes and likely alignment

8 BYGGESEKTORENS KLIMABIDRAG (bnl.no)

9 https://www.iea.org/fuels-and-technologies/building-envelopes

10 Renewables – Global Energy Review 2021 – Analysis - IEA

11 Net Zero by 2050 – Analysis - IEA

12 Clean energy innovation – Energy Technology Perspectives 2020 – Analysis - IEA

13 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32020R0852&from=EN

14taxonomy-regulation-delegated-act-2021-2800-annex-1\_en.pdf (europa.eu)

15 The safeguards entail alignment with the OECD Guidelines for Multinational Enterprises and UN Guiding Principles on Business and Human Rights, including the International Labour Organisation's ('ILO') declaration on Fundamental Rights and Principles at Work, the eight ILO core conventions and the International Bill of Human Rights.

are presented in Appendix 2. The project category sustainable manufacturing and technology has not been assessed as no EU Taxonomy activities could currently be identified.

Relevant EU-Taxonomy activities are:

  • Electricity generation using solar photovoltaic technology
  • Electricity generation from wind power
  • Electricity generation from hydropower
  • District heating/cooling distribution
  • Construction of new buildings
  • Renovation of existing buildings
  • Acquisition and ownership of buildings

The bank informs us that the corporate banking service concept is under review in order to incorporate sustainability and anti-money laundering aspects, and this will include procedures to detect significantly harmful activities under the EU taxonomy. Advisors will assess loans according to the taxonomy criteria via a dedicated interface of the loan assessment module used today. In case non-alignment (including DNSH) is detected, during annual client meetings or otherwise, a new loan will not be included in the green loan portfolio and any existing green loans will be removed from the green loan portfolio.

Acquisition and ownership of new buildings.

The bank has engaged Multiconsult to present evidence that the framework's criteria ensure the financed buildings will be among the top 15% of the national building stock, distinguishing between commercial and residential. According to Multiconsult, Norwegian residential buildings that comply with the Norwegian building code of 2010 (TEK10) and later codes account for less than 15% of the residential building stock. Furthermore, Multiconsult concludes that residential buildings that qualify under the framework represent top 10% of the similar building stock when it comes to energy efficiency while eligible commercial buildings represent between the top 4.9 and 13.6% of similar building stock in Norway. The methodology used by Multiconsult have some pitfalls (see page 16).

Alignment with minimum social safeguards

Social issues and safeguards are integrated into the bank's policies and strategies. The bank reviews a broad set of ESG risks in assessing their corporate loans, including human and workers' rights and financial crimes. ESGrequirements are also set through the bank's credit policy and in guidelines for fund management. Furthermore, the bank has a sustainability policy referring to the guidelines listed in the minimum social safeguards of the EU taxonomy and states that the bank respects human rights and does not contribute to violations of these. All the bank's staff received basic sustainability training in 2020. We also note that the bank' operations are limited to a country "deemed to have robust environmental and social governance, legislation systems and institutional capacity designed to protect their people and the natural environment" as defined by the Equator Principles, and which has ratified all fundamental ILO conventions16. CICERO Green assesses that Sparebank 1 Sørøst-Norge seems to fulfil the minimum social safeguards of the EU Taxonomy.

Main gaps

Sustainable use of water and Pollution prevention and control for the activity Construction of new buildings. According to the issuer, the revised version of the BREEAM Excellent certification will ensure alignment with the EU Taxonomy criteria, including the requirements related to the water appliances and the components and materials used in new buildings. However, given that BREEAM-certification is not a requirement for green loans, there is a likely gap that financed buildings will not follow these DNSH-criteria.

16 Ratifications of ILO conventions: Ratifications for Norway

'Second Opinion' on SpareBank 1 Sørøst-Norge's Green Bond Framework

Governance Assessment

Four aspects are studied when assessing the SpareBank 1 Sørøst-Norge's governance procedures: 1) the policies and goals of relevance to the green bond framework; 2) the selection process used to identify eligible projects under the framework; 3) the management of proceeds; and 4) the reporting on the projects to investors. Based on these aspects, an overall grading is given on governance strength falling into one of three classes: Fair, Good or Excellent. Please note this is not a substitute for a full evaluation of the governance of the issuing institution, and does not cover, e.g., corruption.

SpareBank 1 Sørøst-Norge has strong sustainability policies, and clear emissions reduction targets both for its internal operations and its portfolio, assumed by the bank to be in line with achieving 1.5ºC target by 2050. The bank reports on scope 1, 2 and 3 emissions for the bank's operation, and has a good overview of the emission intensity in the different sectors in its portfolio.

SpareBank 1 Sørøst-Norge is using the TCFD analysis to assess climate risk, is screening its portfolio for physical climate risk and encourages risk exposed clients to adapt resiliency measures. The bank has a strong consensus-

based selection process including life cycle analysis, supply chain and lock-in considerations for new green loans. From 2021 the bank conducts ESG-assessments for all new corporate loans. ESG-requirements are also given in the bank's credit policy and in guidelines for fund management. The bank has a high focus on sustainability training towards the client advisors. Impact reporting will be externally verified, but we see a weakness in that the calculations of environmental impacts from the green buildings category may be overestimated.

The overall assessment of SpareBank 1 Sørøst-Norge's governance structure and processes gives it a rating of Excellent.

Strengths

SpareBank 1 Sørøst-Norge's focus and work on sustainability is a clear strength, demonstrated i.a. through having emission reduction targets for both its internal operation and its portfolio. It is considered a strength that Sparebank 1 Sørøst-Norge has GHG-emission reduction targets for its portfolio aiming at being aligned with a trajectory of achieving 1.5ºC target by 2050. The overview of carbon related credit exposure by sector gives the bank a good starting point to work to reduce the GHG-emissions in its portfolio. CICERO Green encourages the bank to establish reporting of GHG-emissions for its loan portfolio.

The bank's work on climate risk assessment is commendable, both when it comes to identifying the physical risks and suggesting adaptation measures for customers identified to have high climate risks. Linking the willingness to implement adaptive measures with pricing of loans is reducing the bank's financial risks related to climate change and is considered best practice. The bank is also reporting according to the TCFD-guidelines. The bank is likely aligned with the DNSH-criteria related to climate change adaptation, which is relevant for all EU activities in the bank's green framework.

SpareBank 1 Sørøst-Norge has a high focus on sustainability training of the bank's employees, making the advisors better equipped to be a competent sparring partner for its customers on sustainability.

It is a strength that fossil fuel related equipment is explicitly excluded across all categories, and that the framework may finance technologies replacing fossil fuels in sectors where cleaner technologies are not yet widely in use. It is considered a strength that SpareBank 1 Sørøst-Norge is cooperating with the local industry to improve their work on sustainability through offering favorable credit terms on eligible projects. The issuer has established ambitious energy, water and GHG-emissions thresholds.

Weaknesses

We find a weakness in the framework's reporting on impacts from the green buildings category. For both new and existing buildings, the issuer plans on reporting energy use (in kWh/m2 or in percentage terms) relative to national standards or Norwegian average. There is thus a risk that the environmental benefits of the financed buildings are overestimated, and even more so if the calculation is based on the Norwegian average17. There is no certainty that the financed existing buildings directly replace buildings with weaker energy performance. For newly constructed buildings, it makes sense to compare their energy use to that required by the regulation. The impact reporting would be more transparent if the issuer reported the actual energy use of the financed buildings. The bank should make sure to use the same grid factors when they report impacts as in annual reporting.

Pitfalls

Renovation of existing buildings is key in order to succeed in the transition to a low carbon future. The most important issue when it comes to the real estate sector from an environmental perspective is what could be done to make the existing building stock more energy efficient. The 30% improvement criteria is commensurable. For buildings built in 2021or later, buildings with an energy consumption 10% lower than national building codes (TEK17) are eligble. Investors should be aware that NZEB is not established in Norway and that regulations on energy efficiency for new buildings have not been tightened since 2016, and as such a 10% improvement is not considered ambitious.

Even though the bank has included BREEAM-NOR Excellent and EPC A as eligible building criteria, the framework also opens for providing green loans to buildings with no additional energy requirements. The bank has engaged Multiconsult to present evidence that the framework's criteria ensure the financed buildings will be among the top 15% of the national building stock, distinguishing between commercial and residential buildings. In their assessment Multiconsult has considered the building stock statistics, historic building code development and building customs over the years, and has examined the EPC-system and how the database of certificates may be used to identify the bank's eligibility criteria. Net energy demand is calculated using standard building models identical to the models used for defining the building codes (TEK10/TEK17). Multiconsult finds that changes in the Norwegian building code have resulted in increasingly energy efficient buildings, and that as of 2020, 10% of Norwegian residential buildings are built following TEK10 or a newer building code, within 15% and thus being eligible according to the SpareBank 1 Sørøst-Norge criterion. The methodology used by Multiconsult however has some pitfalls:

  • The construction year will alone be used to identify eligible residential buildings. EPC is only required when a building is sold or rented, there is uncertainty about the actual energy performance of the entire building stock. Since there is no requirement to provide evidence that the buildings are built according to the regulations, only to document construction year, there is no guarantee that the buildings comply with the regulation.

'Second Opinion' on SpareBank 1 Sørøst-Norge's Green Bond Framework

17 The most recent available official data from Statistics Norway is from 2012 and 2011. The average energy use for residential buildings in 2012 was 181 kWh/m2 (in use). The average energy use in commercial buildings in 2011 was 230 kWh/m2 (in use). Average energy use by all real estate activities (2011) in Norway: 179 kWh/m2 (in use) (Statistics Norway). (see: https://cicero.oslo.no/file/2/sectorbriefs\_realestate\_17\_12.pdf/download )

  • Some buildings built after TEK 10 (that would be eligible under the framework) have received an EPC D. The Norwegian EPC system requires every apartment to be certified separately, however for apartment buildings the grading is set for an average apartment. This might lead to that a building built according to TEK 10 includes units with high heat losses and lower energy labels. Examples provided by Multiconsult are as low as energy label EPC C and D, and even in rare cases EPC E. The bank could consider screening for buildings which can be considered green.
  • It is unclear to CICERO Green whether energy efficiency measures implemented recently supported by Enova in existing building stocks (solar panels, heat pumps etc.) are accounted for in the assessment.
  • It will be important that the assessment is regularly updated to capture energy improvements in the building stock.

In a low carbon 2050 perspective, the energy performance of buildings is expected to be improved, with passive and plus house technologies becoming mainstream and the energy performance of existing buildings greatly improved through refurbishments. In the Norwegian context, around half of the emissions comes from energy use, and the other half from embodied emissions. As the energy performance of buildings improves, the embodied emissions in building materials are becoming a more significant share of a building's climate footprint and should be managed.

Even though it is considered a strength that SpareBank 1 Sørøst-Norge is cooperating with the local industry to improve their work on sustainability, the project category "Sustainable manufacturing and technology" is however very broad. The selection process therefore becomes very important. There is a risk that projects could be financed that are part of an emission intensive supply chain. The issuer is therefore encouraged to screen for improvements that in a longer perspective do not lock-in obsolete technologies.

Appendix 1: Referenced Documents List

Document
Number
Document Name Description
1 SpareBank 1 Sørøst-Norge's Green Bond
Framework, Dated December 2021
Green Bond Framework
2 SpareBank 1 BV annual report 2020. Annual report from 2020.
3 SpareBank 1 BV, Bærekraftspolicy,
2020.
SpareBank 1 BV's Sustainability Policy, 2021-
2023.
4 SpareBank 1 BV, Etiske retningslinjer,
dated 2020.
SpareBank 1 BV Code of Conduct.
5 Retningslinjer for bærekraftig distribusjon og
anbefaling av verdipapirfond i SpareBank 1,
dated May 2021.
ESG guidance for fund management.

Appendix 2: EU Taxonomy criteria and alignment

Complete details of the EU taxonomy criteria are given in taxonomy-regulation-delegated-act-2021-2800-annex-1\_en.pdf (europa.eu)

Electricity generation using solar photovoltaic technology

Framework
activity
Renewable energy
Taxonomy activity Electricity generation using solar photovoltaic (PV) technology
(NACE codes
D35.11 and F 42.22)
EU Technical mitigation criteria Comments on alignment CICERO Green's
comments on alignment
Mitigation criteria
The activity generates electricity from solar PV technology.
Information provided by the issuer

Green loans can be provided to renewable energy
plants and installations, as well as manufacturing of
relating technologies and equipment, within solar
power.

Both roof-top and standalone solar PV can qualify.

Solar power
is assumed to contribute substantially to
climate change mitigation.
Likely aligned.
EU Taxonomy DNSH-criteria Comments on alignment Alignment
Climate change
adaptation
The physical climate risks that are material to the activity have been
identified (chronic and acute, related to temperature, wind, water, and
soil) by performing a robust climate risk and vulnerability assessment
with the following steps18:
(a)
screening of the activity to identify which physical climate risks
from the list in Section II of this Appendix may affect the
performance of the economic activity during its expected
lifetime;
(b)
where the activity is assessed to be exposed to physical climate
risks, a climate risk and vulnerability assessment to assess the
materiality of the physical climate risks on the economic
activity;
(c)
an assessment of adaptation solutions that can reduce the
identified physical climate risk.
Please see under Construction of new buildings. Likely aligned.

18 The Taxonomy is referring to Appendix A in the Taxonomy Annex 1.

The climate projections and assessment of impacts are based on best
practice and available guidance and take into account the state-of
the-art science for vulnerability and risk analysis and related
methodologies in line with the most recent Intergovernmental Panel
on Climate Change reports, scientific peer-reviewed publications,
and open source or paying models.
For existing activities and new activities using existing physical
assets, the economic operator implements physical and non-physical
solutions ('adaptation solutions'), over a period of time of up to five
years, that reduce the most important identified physical climate risks
that are material to that activity. An adaptation plan for the
implementation of those solutions is drawn up accordingly.
For new activities and existing activities using newly built physical
assets, the economic operator integrates the adaptation solutions that
reduce the most important identified physical climate risks that are
material to that activity at the time of design and construction and has
implemented them before the start of operations.
The adaptation solutions implemented do not adversely affect the
adaptation efforts or the level of resilience to physical climate risks of
other people, of nature, of cultural heritage, of assets and of other
economic activities; are consistent with local, sectoral, regional or
national adaptation strategies and plans; and consider the use of
nature-based solutions or rely on blue or green infrastructure to the
extent possible.
Sustainable use and
protection of water
and marine
resources
N/A N/A N/A
Transition to a
circular economy

The activity assesses availability of and, where feasible, uses
equipment and components of high durability and recyclability
and that are easy to dismantle and refurbish.
Information provided by the issuer

The bank's competence-building effort as part of its
new strategy will, for all advisors granting loans,
highlight EU taxonomy technical criteria. In the case
of circular economy and solar power, the focus will be
on durability and recyclability of solar modules and
other electric and electronic equipment. For all new
loans to solar power, advisors will ask questions
related to re-use and recycling. It is envisaged that
advisors will assess loans according to the taxonomy
criteria, including the circular economy criteria, via a
Likely aligned.

dedicated interface of the loan assessment module
used today.
Pollution
prevention and
control.
N/A N/A N/A
Protection and
restoration of
biodiversity and
ecosystems

An Environmental Impact Assessment (EIA) or screening has
been completed in accordance with Directive 2011/92/EU19, or in
accordance with national provisions.

Where an EIA has been carried out, the required mitigation and
compensation measures for protecting the environment are
implemented.

For sites/operations located in or near biodiversity-sensitive areas
(including the Natura 2000 network of protected areas, UNESCO
World Heritage sites and Key Biodiversity Areas, as well as other
protected areas), an appropriate assessment, where applicable, has
been conducted and based on its conclusions the necessary
mitigation measures are implemented.
Relevant
contextual
information

Not applicable for roof-top solar systems.

Solar power plants for the production and sale of
electricity are subject to licensing
from NVE
(Norwegian Water Resources and Energy Directorate)
pursuant to the Energy Act.

Solar power plants subject to a license are also
covered by the Planning and Building Act's
regulations on environmental impact assessment, but it
is
unclear whether an EIA is needed.

Solar power plants with a voltage of 1000 V AC /
1500 V DC or less do not need a license according to
the Energy Act.
Information provided by the issuer

The bank's credit handbook will prohibit loans to
activities in wetlands and biodiversity sensitive areas
("verneområder").
Likely aligned.

19 The EU-Directive on the assessment of the effects of certain public and private projects on the environment (the EIA-directive). EUR-Lex - 32011L0092 - EN - EUR-Lex (europa.eu)

Electricity generation from wind power

Framework
activity
Renewable energy
Taxonomy
activity
Electricity generation from wind power (NACE codes
D35.11 and F 42.22)
EU Technical mitigation criteria Comments on alignment CICERO Green's
comments on alignment
Mitigation
criteria

The activity generates electricity from wind power.
Information provided by the issuer

Green loans can be provided to renewable energy
plants and installations, as well as manufacturing of
relating technologies and equipment, within wind
power.

Both onshore and offshore wind projects can qualify.

Wind power is assumed to contribute substantially to
climate change mitigation.
Likely aligned.
EU Taxonomy DNSH-criteria
Comments on alignment
Climate change
adaptation
Please see under Construction of new buildings. Alignment
Sustainable use
and protection of
water and marine
resources

In case of construction of offshore wind, the activity does not
hamper the achievement of good environmental status as set out in
Directive 2008/56/EC20 of the European Parliament and of the
Council, requiring that the appropriate measures are taken to
prevent or mitigate impacts in relation to that Directive's
Descriptor 11 (Noise/Energy), laid down in Annex I to that
Directive, and as set out in Commission Decision (EU)
2017/848159 in relation to the relevant criteria and
methodological standards for that descriptor.
Relevant
contextual
information

Wind farms are regulated by NVE

New wind farms in addition need an approved plan for
environment, transport, and construction (MTA-plan),
including input on how to minimize landscape changes
and noise. Offshore windfarms are regulated by the
Ocean Energy Act (Havenergiloven), also managed by
NVE.
Information provided by the issuer

The bank's competence-building effort as part of its
new strategy will, for all advisors granting loans,
highlight EU taxonomy technical criteria. In the case
of water & marine resources and offshore wind, the
focus will be on key aspects of the project's EIA. For
all new loans, advisors currently ask questions related
to whether the activity has significant nature risk
impact. It is envisaged that advisors will assess loans
according to the taxonomy criteria, including the
water & marine resources criteria, via a dedicated
interface of the loan assessment module used today.
Likely aligned.

20 The EU-Directive establishing a framework for community action in the field of marine environmental policy, EUR-Lex - 32008L0056 - EN - EUR-Lex (europa.eu)

Transition to a
circular economy

The activity assesses availability of and, where feasible, uses
equipment and components of high durability and recyclability and
that are easy to dismantle and refurbish.
Information provided by the issuer

For all new loans within wind power, advisors will
ask questions related re-use and recycling. The bank's
competence-building effort as part of its new strategy
will, for all advisors granting loans, highlight EU
taxonomy technical criteria. In the case of circular
economy and wind power, the focus will be on
durability and recyclability of wind turbine blades and
other electric and electronic equipment. It is
envisaged that advisors will assess loans according to
the taxonomy criteria, including the circular economy
criteria, via a dedicated interface of the loan
assessment module used today.
Protection and
restoration of
biodiversity and
ecosystems

An Environmental Impact Assessment (EIA) or screening has been
completed in accordance with Directive 2011/92/EU21, or in
accordance with national provisions.

Where an EIA has been carried out, the required mitigation and
compensation measures for protecting the environment are
implemented.

For sites/operations located in or near biodiversity-sensitive areas
(including the Natura 2000 network of protected areas, UNESCO
World Heritage sites and Key Biodiversity Areas, as well as other
protected areas), an appropriate assessment, where applicable, has
been conducted and based on its conclusions the necessary
mitigation measures are implemented.
Relevant
contextual
information

Wind turbines for the production of electricity are
normally subject to licensing from NVE pursuant to
the Energy Act. Plants consisting of up to 5 wind
turbines with a total installed capacity of less than 1
MW are exempt from the licensing obligation.

Wind power installations where installed effect
exceed 10 MW need to conduct an EIA as a part of
the licensing process, in accordance with the Planning
and Building Act. This includes implementation of
mitigative measures.
Likely aligned.

In case of offshore wind, the activity does not hamper the
achievement of good environmental status as set out in Directive
2008/56/EC, requiring that the appropriate measures are taken to
prevent or mitigate impacts in relation to that Directive's
Descriptors 1 (biodiversity) and 6 (seabed integrity), laid down in
Annex I to that Directive, and as set out in Decision (EU)
2017/848
in relation to the relevant criteria and methodological standards for
those descriptors.
Information provided by the issuer

The bank's credit handbook will prohibit loans to
activities in wetlands and biodiversity sensitive areas
("verneområder").

21 The EU-Directive on the assessment of the effects of certain public and private projects on the environment (the EIA-directive). EUR-Lex - 32011L0092 - EN - EUR-Lex (europa.eu)

Electricity generation from hydropower

Framework
activity
Renewable energy
Taxonomy
activity
Electricity generation from hydropower (NACE Code D35.11 and F42.22)
Taxonomy
version
EU Technical mitigation criteria Comments on alignment CICERO Green's
comments on alignment
Mitigation
threshold
The activity complies with either of the following criteria:
a)
the electricity generation facility is a run-of-river plant and does not
have an artificial reservoir;
b)
the power density of the electricity generation facility is above 5
W/m2
;
c)
the life-cycle GHG emissions from the generation of electricity from
hydropower, are lower than 100gCO2e/kWh22.
Information provided by the issuer

Green loans can be provided to hydropower with a
power density above 5W/m2, or life-cycle emissions
below 100g CO2e/kWh, or run-of-river plants
without artificial reservoirs.

New hydropower developments can be funded, as
long as the DNSH-criteria are met, and the
development is not in a contentious area with local
opposition.

A study performed in 2019 by the Norwegian
Institute for Sustainability Research (NORSUS) on
Norwegian hydropower, indicates average life-cycle
emissions of around 3.3g CO2e/kWh. In addition, the
study notes that hydropower plants in Norway tend
to be located at high altitudes where there is little
vegetation as well as colder climate, which leads
to
limited extra methane emissions from algae growth
with could develop in the water storage basin where
the climate is warmer23.
Likely aligned.
EU Taxonomy DNSH-criteria Comments on alignment Alignment
Climate change
adaptation
Please see under Construction of new buildings.
Sustainable use
and protection of
water and marine
resources
The activity complies with the provisions of Directive 2000/60/EC24,
1.
in particular with all the requirements laid down in Article 4 of the
directive.
Relevant contextual information

The construction of energy production facilities
larger than 1
MW needs a license from the
Norwegian Water Resources and Energy Directorate
(NVE) according to the "Energy Act" and the
Likely aligned.

22 The life-cycle GHG emissions are calculated using Recommendation 2013/179/EU or, alternatively, using ISO 14067:2018162, ISO 14064-1:2018163 or the G-res tool. Quantified life-cycle GHG emissions are verified by an independent third party.

23 AR-01.19-The-inventory-and-life-cycle-data-for-Norwegian-hydroelectricity.pdf (norsus.no)

24 The Water Framework Directive, EUR-Lex - 32000L0060 - EN - EUR-Lex (europa.eu)

2.
For operation of existing hydropower plants, including
"Water Resources Act". Conditions and rules of
refurbishment activities to enhance renewable energy or energy operation will be stated in the license.
storage potential, the activity complies with the following criteria: Mitigation of negative environmental impacts as well
as impacts on biodiversity, surrounding areas, and
2.1. In accordance with Directive 2000/60/EC and in particular Articles 4
and 11 of that Directive, all technically feasible and ecologically relevant cultural heritages are important elements in attaining
mitigation measures have been implemented to reduce adverse impacts necessary licenses from NVE.
on water as well as on protected habitats and species directly dependent Companies need to complete an EIA and to
on water. demonstrate
alignment with the EU Water
Framework Directive (WFD). For newer
2.2. Measures include, where relevant and depending on the ecosystems installations, minimum requirements include
naturally present in the affected water bodies: minimum water flow, functional fish migration
(a)
measures to ensure downstream and upstream fish migration (such
pathways as well as safeguards for biodiversity and
as fish friendly turbines, fish guidance structures, state-of-the-art local ecosystems.
River basin management (RBM) is conducted on a
fully functional fish passes, measures to stop or minimise operation regional level, and hydropower plants need to be
and discharges during migration or spawning);
(b)
measures to ensure minimum ecological flow (including mitigation
incorporated in the existing river basin management
of rapid, short-term variations in flow or hydro-peaking operations) plans. This is regulated in the WFD.
and sediment flow; Old hydropower plants do not have licenses but must
(c)
measures to protect or enhance habitats
comply with and are subject to the same legal
requirements and the same audit regime as plants
2.3. The effectiveness of those measures is monitored in the context of with a license.
the authorisation or permit setting out the conditions aimed at achieving Smaller energy projects with lesser environmental
impacts may be handled through simplified handling
good status or potential of the affected water body. procedures.
NVE is
carrying out audits to monitor performance,
3. For construction of new hydropower plants, the activity complies with and has started an assessment of all licenses to
the following criteria: ensure alignment with updated requirements.
3.1. In accordance with Article 4 of Directive 2000/60/EC and in To receive a license for a new hydropower plant, the
particular paragraph 7 of that Article, prior to construction, an impact
assessment of the project is carried out to assess all its potential impacts Water Resource Act (§25) needs to be fulfilled,
on the status of water bodies within the same river basin and on protected requiring that the overall consequences locally,
regionally and nationally are investigated. This will
habitats and species directly dependent on water, considering in particular be a part of the application to receive a and focus on
migration corridors, free-flowing rivers or ecosystems close to e.g., the environment, nature and biodiversity. A
undisturbed conditions. license will only be issued if the advantages of the
development are outweighing the disadvantages.
The assessment is based on recent, comprehensive and accurate data, Consequences must be adapted to the expected
including monitoring data on biological quality elements that are lifespan of the development.
specifically sensitive to hydromorphological alterations, and on the
expected status of the water body as a result of the new activities, as
compared to its current one. Information provided by the issuer
For all new loans, advisors currently ask a question
It assesses in particular the cumulated impacts of this new project with related to nature risk.
other existing or planned infrastructure in the river basin.
3.2. On the basis of that impact assessment, it has been established that
the plant is conceived, by design and location and by mitigation
measures, so that it complies with one of the following requirements:
(a)
the plant does not entail any deterioration nor compromises the
achievement of good status or potential of the specific water body it
relates to;
(b)
where the plant risks to deteriorate or compromise the achievement
of good status/potential of the specific water body it relates to, such
deterioration is not significant, and is justified by a detailed cost
benefit assessment demonstrating both of the following: (i) the
reasons of
overriding public interest or the fact that benefits
expected from the planned hydropower plant outweigh the costs
from deteriorating the status of water that are accruing to the
environment and to society; (ii) the fact that the overriding public
interest or the benefits expected from the plant cannot, for reasons of
technical feasibility or disproportionate cost, be achieved by
alternative means that would lead to a better environmental outcome
(such as refurbishing of existing hydropower plants or use of
technologies not disrupting river continuity).
3.3. All technically feasible and ecologically relevant mitigation measures
are implemented to reduce adverse impacts on water as well as on
protected habitats and species directly dependent on water. Mitigation
measures include, where relevant and depending on the ecosystems
naturally present in the affected water bodies:
(a)
measures to ensure downstream and upstream fish migration (such
as fish friendly turbines, fish guidance structures, state-of the-art
fully functional fish passes, measures to stop or minimise operation
and discharges during migration or spawning);
(b)
measures to ensure minimum ecological flow (including mitigation
of rapid, short-term variations in flow or hydro-peaking operations)
and sediment flow;
(c)
measures to protect or enhance habitats. The effectiveness of those
measures is monitored in the context of the authorisation or permit
setting out the conditions aimed at achieving good status or potential
of the affected water body.
3.4. The
plant does not permanently compromise the achievement of
good status/potential in any of the water bodies in the same river basin

The bank's competence-building effort as part of its
new strategy will, for all advisors granting loans,
highlight EU taxonomy technical criteria. In the case
of water resources and hydropower, we envisage that
an additional industry-specific question will
be asked
regarding main impacts on water bodies, habitats and
species, and mitigating actions.
It is envisaged that advisors will assess loans
according to the taxonomy criteria, via a dedicated
interface of the loan assessment module used today.
district.

3.5. In addition to the mitigation measures referred to above, and where
relevant, compensatory measures are implemented to ensure that the
project does not increase the fragmentation of water bodies in the same
river basin district. This is achieved by restoring continuity within the
same river basin district to an extent that compensates the disruption of
continuity, which the planned hydropower plant may cause.
Compensation starts prior to the execution of the project.
Transition to a
circular economy
N/A N/A N/A
Pollution
prevention and
control.
N/A N/A N/A
Protection and
restoration of
biodiversity and
ecosystems

An Environmental Impact Assessment (EIA) or screening has been
completed in accordance with Directive 2011/92/EU25, or in
accordance with national provisions.

Where an EIA has been carried out, the required mitigation and
compensation measures for protecting the environment are
implemented.

For sites/operations located in or near biodiversity-sensitive areas
(including the Natura 2000 network of protected areas, UNESCO
World Heritage sites and Key Biodiversity Areas, as well as other
protected areas), an appropriate assessment, where applicable, has
been conducted and based on its conclusions the necessary
mitigation measures are implemented26.
Relevant contextual information

The construction of energy production facilities
larger than 1
MW
is subject to licensing from the
NVE pursuant
to the Energy Act and the Water
Resources Act.

To receive a license the company needs to complete
an EIA
in accordance with the Planning and Building
Act, including implementation of mitigative
measures.
Information provided by the issuer:

The bank's credit handbook will prohibit loans to
activities in wetlands and biodiversity sensitive areas
("verneområder").
Likely aligned.

25 The EU-EIA-directive. EUR-Lex - 32011L0092 - EN - EUR-Lex (europa.eu)

26 Practical guidance is contained in Commission notice C/2018/2619 'Guidance document on the requirements for hydropower in relation to EU nature legislation' (OJ C 213, 18.6.2018, p. 1).

District heating/cooling distribution

Framework
activity
Renewable energy
Taxonomy
activity
District heating/cooling distribution (NACE D35.30)
Taxonomy EU Technical mitigation criteria Comments on alignment CICERO Green's
comments on alignment
version
Mitigation criteria
The activity complies with one of the following criteria:
(a)
for construction and operation of pipelines and associated
infrastructure for distributing heating and cooling, the system
meets the definition of efficient district heating and cooling
systems laid down in Article 2, point 4116, of Directive
2012/27/EU27;
(b)
for refurbishment of pipelines and associated infrastructure for
distributing heating and cooling, the investment that makes the
system meet the definition of efficient district heating or cooling
laid down in Article 2, point 4128, of Directive 2012/27/EU starts
within a three year period as underpinned by a contractual
obligation or an equivalent in case of operators in charge of both
generation and the network;
(c)
the activity is the following:
(i)
modification to lower temperature regimes;
(ii)
advanced pilot systems (control and energy management
systems, Internet of Things).
Information provided by the issuer:

Loans financing the acquisition, construction,
development, operation, maintenance, and
improvement of facilities and related infrastructure
for district heating and cooling where at least [95%]
of the fuel comes from renewable sources such as
locally supplied forestry waste and residues, recycled
wood waste, or waste heat from nearby industries can
be funded using green proceeds.
According to the bank, the selection criteria ensure

locally supplied materials, where Norwegian
standards and regulations apply, ensuring sustainable
sourcing.
EU Taxonomy DNSH-criteria Comments on alignment Alignment
Climate change
adaptation
Please see under Construction of new buildings.
Sustainable use
and protection of
water and marine
resources

Environmental degradation risks related to preserving water
quality and avoiding water stress are identified and addressed with
the aim of achieving good water status and good ecological
potential as defined in Article 2, points (22) and (23), of
Regulation (EU) 2020/85229, in accordance with Directive
2000/60/EC30 of the European Parliament and of the Council and
a water use and protection management plan, developed
Relevant contextual information

District heating and cooling systems are covered by
the Energy Act, and the licensing obligation is
triggered if the system supplies external consumers
and has a capacity of more than 10 MW.

An EIA must be carried out if the system has a
capacity of 150 MW or more. Waste incineration
Likely aligned.

27 The EU-directive on Energy Efficiency, EUR-Lex - 32012L0027 - EN - EUR-Lex (europa.eu)

28 "efficient district heating and cooling' means a district heating or cooling system using at least 50 % renewable energy, 50 % waste heat, 75 % cogenerated heat or 50 % of a combination of such energy and heat;"

29 The regulation on the establishment of a framework to facilitate sustainable investment. EUR-Lex - 32020R0852 - EN - EUR-Lex (europa.eu)

30 The Water Framework Directive. EUR-Lex - 32000L0060 - EN - EUR-Lex (europa.eu)

thereunder for the potentially affected water body or bodies, in
consultation with relevant stakeholders.

Where an Environmental Impact Assessment is carried out in
accordance with Directive 2011/92/EU31 of the European
Parliament and of the Council and includes an assessment of the
impact on water in accordance with Directive 2000/60/EC, no
additional assessment of impact on water is required, provided the
risks identified have been addressed.
plants are subject to an EIA assessment if the capacity
is more than 100 tonnes of waste per day.

District heating and cooling installations under
50
MW are regulated by the "Pollution control
regulation", and installations over 50 MW need a
license from the Norwegian Environment Agency.

Measures to avoid degradation of water are included
in the permit and in the EIA-process.
Information provided by the issuer
The approximate size of the facilities is 1-6 MW.


For all new loans, advisors currently ask a question
related to nature risk.
The bank's competence-building effort as part of its

new strategy will, for all advisors granting loans,
highlight EU taxonomy technical criteria. It is
envisaged that advisors will assess loans according to
the taxonomy criteria, including the circular economy
criteria, via a dedicated interface of te loan assessment
module used today.
Transition to a
circular economy
N/A N/A N/A
Pollution
prevention and
control.

Fans, compressors, pumps and other equipment used which is
covered by Directive 2009/125/EC32 comply, where relevant,
with the top class requirements of the energy label, and otherwise
comply with implementing regulations under that Directive and
represent the best available technology.
Information provided by the issuer

The emission limits for emissions of NOx, SO2, CO
and dust from incineration plants related to district
heating are lowered on 20 December 2121 (cf.
Pollution Control Regulations § 27-10, § 27-11, §
27-22, and appendix 2). The limit values are lower
for plants over 5MW, and the deadline for phasing in
is 2025
(2030 for smaller plants). The bank will
follow up clients to ensure compliance with the
phase-in of such limits.
Likely aligned.
Protection and
restoration of
biodiversity and
ecosystems

An Environmental Impact Assessment (EIA) or screening has
been completed in accordance with Directive 2011/92/EU33, or in
accordance with national provisions.
Relevant contextual information
An EIA must be carried out if the system has a

capacity of 150 MW or more, including
implementation of mitigative measures.
Likely aligned.

31 The EU-EIA-directive. EUR-Lex - 32011L0092 - EN - EUR-Lex (europa.eu)

32 The EU-directive on establishing a framework for the setting of ecodesign requirements for energy-related products. EUR-Lex - 32009L0125 - EN - EUR-Lex (europa.eu)

33 The EU-EIA-directive. EUR-Lex - 32011L0092 - EN - EUR-Lex (europa.eu)


Where an EIA has been carried out, the required mitigation and
compensation measures for protecting the
environment are
implemented.

For sites/operations located in or near biodiversity-sensitive areas

Waste incineration plants are subject to an EIA
assessment if the capacity is more than 100 tonnes of
waste per day.
(including the Natura 2000 network of protected areas, UNESCO
World Heritage sites and Key Biodiversity Areas, as well as other
protected areas), an appropriate assessment, where applicable, has
been conducted and based on its conclusions the necessary
mitigation measures are implemented34.
Information provided by the issuer

The bank's credit handbook will prohibit loans to
activities in wetlands and biodiversity sensitive areas
("verneområder").

For all new loans, advisors currently ask a question
related to nature risk.

34 Practical guidance is contained in Commission notice C/2018/2619 'Guidance document on the requirements for hydropower in relation to EU nature legislation' (OJ C 213, 18.6.2018, p. 1).

Construction of new buildings

Framework Green buildings
activity
Taxonomy activity
Construction of new buildings (NACE Code F41.1, F41.2)
EU Technical mitigation criteria Comments on alignment CICERO Green's
comments on alignment
Technical
screening
criteria
Constructions of new building,
eligible if:

The Primary Energy Demand is at least 10
% lower than the
threshold set for the nearly zero-energy building (NZEB)
requirements in national regulation. The energy performance is
certified using an as built Energy Performance Certificate (EPC).
For buildings larger than 5000 m2, upon completion,
the building

resulting from the construction undergoes testing for air-tightness
and thermal integrity, and any deviation in the levels of performance
set at the design stage or defects in the building envelope are
disclosed to investors and clients.
As an alternative; where robust
and traceable quality control processes are in place during the
construction process this is acceptable as an alternative to thermal
integrity testing.

For buildings larger than 5000 m2, the life cycle Global Warming
Potential of the building resulting from the construction has been
calculated for each stage in the life cycle and is disclosed to
investors and clients on demand.
Information provided by the issuer:
The following eligibility criteria apply:
Buildings built in 2021 or later

Buildings with an energy consumption that is 10%
lower than national minimum requirements
(TEK17)35; or

Buildings with BREEAM-NOR 3.0
Excellent
certificate.
For buildings larger than 5.000m2, (i) upon completion
having undergone testing for air-tightness and thermal
integrity (unless robust and traceable quality control
processes are in place during construction), and (ii)
calculation of the Global Warming Potential
for each
stage of
the life cycle.
The bank's competence-building effort as part of its
new strategy will, for all advisors granting loans,
highlight EU taxonomy technical criteria. In the case of
construction of new buildings, this will include NZEB
requirements, and requirements relating to building
size. These technical requirements will also be featured
in the future dedicated taxonomy interface of the loan
Likely aligned.
EU Taxonomy DNSH-criteria assessment module used today.
Comments on alignment
Alignment
Climate change
adaptation
The physical climate risks that are material to the activity have been
identified (chronic and acute, related to temperature, wind, water, and
soil) by performing a robust climate risk and vulnerability assessment
with the following steps36:
Information provided by the issuer
The bank is reporting according to the TCFD
and has
assessed phyiscal climate risk for its portfolio on an
asset basis.
Likely aligned.

35 NZEB requirements are yet to be implemented in Norway, and therefore this framework uses the latest Norwegian building code available (TEK17) as a proxy.

36 The Taxonomy is referring to Appendix A in the Taxonomy Annex 1.

screening of the activity to identify which physical climate risks
(d)
from the list in Section II of this Appendix may affect the
performance of the economic activity during its expected lifetime;
(e)
where the activity is assessed to be exposed to physical climate
risks, a climate risk and vulnerability assessment to assess the
materiality of the physical climate risks on the economic activity;
(f)
an assessment of adaptation solutions that can reduce the identified
physical climate risk.
The climate projections and assessment of impacts are based on best
practice and available guidance and take into account
the state-of-the-art
science for vulnerability and risk analysis and related methodologies in
line with the most recent Intergovernmental Panel on Climate Change
reports, scientific peer-reviewed publications, and open source or
paying models.
For existing activities and new activities using existing physical assets,
the economic operator implements physical and non-physical solutions
('adaptation solutions'), over a period of time of up to five years, that
reduce the most important identified physical climate risks that are
material to that activity. An adaptation plan for the implementation of
those solutions is drawn up accordingly.
For new activities and existing activities using newly built physical
assets, the economic operator integrates the adaptation solutions that
reduce the most important identified physical climate risks that are
material to that activity at the time of design and construction and has
implemented them before the start of operations.
The adaptation solutions implemented do not adversely affect the
adaptation efforts or the level of resilience to physical climate risks of
other people, of nature, of cultural heritage, of assets and of other
economic activities; are consistent with local, sectoral, regional or
national adaptation strategies and plans; and consider the use of nature
based solutions or rely on blue or green infrastructure to the extent
possible.
The bank asks specific questions on physical climate
risks
for all new loans. Furthermore the bank has a
strategy for 2022-23 to increase training for the
advisors to enable the
clients to reduce the physical
climate risk.
The competence building effort will, for staff assessing
such loans, include topics such as (but not limited to)
1) specific locations in the
market area with high
physical climate risk (and hence the risk of
accepting
newbuilds in such locations);
2) the importance of increasing the lifetime of
newbuilds through flexible interior design and design
for reuse;
3) the implications of accepting newbuild close to
vulnerable biodiversity areas;
4) how choosing low-carbon building materials reduces
emissons immediately, and hence need to be balanced
against energy-efficiency measures yielding gradual
effects over a longer time period.
Regarding adapation, the bank has identified
geographical areas where adaptation measures may be
needed. It will use Norkart and/or Eiendomsverdi to
provide data on physical climate risk of the bank's retail
and corporate portfolio, with results expected next
month. The expected output is GPS coordinates for all
buildings linked to the bank's loan exposure, matched
with physical climate risk map data. Based on these
data, the
bank
plans
to identify
the customers
with the
highest climate risks, and approach them to understand
to what extent they have already taken adaptation
measures.
The bank will offer solutions for the
customers with material climate risk that have not yet
taken adaptive measures. Depending on their
willingness to introduce adaptive measures the bank
may adjust the pricing of the loan to reflect the
increased risk.
Sustainable use and
protection of water
and marine
resources

Where installed, except for installations in residential building units,
the
specified water use for the following water appliances are
attested by
product datasheets, a building certification or an existing
Relevant contextual information

Construction of buildings will normally not require
an EIA, as the area has already been made
available for new construction in the municipality
Likely partly aligned.

product label37 in the Union, in accordance with the technical
specifications:
(a)
wash hand basin taps and kitchen taps have a maximum water
flow of 6 litres/min;
(b)
showers have a maximum water flow of
8 litres/min;
(c)
WCs, including suites, bowls and flushing cisterns, have a full
flush volume of a maximum of 6 litres and a maximum
average
flush volume of 3,5 litres;
(d)
urinals use a maximum of 2
litres/bowl/hour. Flushing urinals
have a maximum full flush volume of 1 litre.
To avoid impact from the construction site, the activity complies with the
criteria in the EU Water Framework Directive38.
Where an
Environmental Impact Assessment is carried out in accordance with
Directive 2011/92/EU39 and includes an assessment of the impact on
water in accordance with the Water Framework Directive, no additional
assessment of impact on water is required, provided the risks identified
regulation plans.
This includes a plan for impacts
on water sources.
Information provided by the issuer
It is envisaged that advisors will assess loans according
to the taxonomy criteria, including the circular
economy criteria, via a
dedicated interface of the loan
assessment module used today.
The bank provides better loan conditions for
commercial real estate certified BREEAM
Excellent/Outstanding. According to the bank's
dialogue with the Norwegian Green Building Council
(Grønn Byggallianse) it is envisaged that revised
BREEAM Excellent criteria will be fully aligned with
the EU taxonomy technical criteria.
have been addressed. As BREEAM-certification is not a requirement, the
bank cannot guarantee that the requirements related to
sustainable use of water will be met
for buildings not
certified.
Transition to a
circular economy
(circular economy)

At
least 70 % (by weight) of the non-hazardous construction and
demolition waste (excluding naturally occurring material40)
generated on the construction site is prepared for re-use, recycling
and other material recovery, including backfilling operations using
waste to substitute other materials.

Operators limit waste generation in processes related to construction
in accordance with the EU Construction and
and demolition
Demolition Waste Management Protocol and taking into account
best available techniques and using selective demolition to enable
removal and safe handling of hazardous substances and facilitate
reuse and high-quality recycling by selective removal of materials,
using available sorting systems for construction and demolition
waste.

Building designs and construction techniques support circularity and
in particular demonstrate how they are designed to be more resource
Information provided by the issuer
It is envisaged that advisors will assess loans according
to the taxonomy criteria, including the circular
economy criteria, via a dedicated interface of the loan
assessment module used today.
The bank intends to revise the current industry-specific
question "I hvilken grad er prosjektet rigget for ombruk
og resirkulering av materialer?" to include a to what
degree the real estate company can confirm that
all
waste is sorted, weighted and that at least 70% of the
non-hazardous waste is prepared for re-use, recycling
and other material recovery (including
backfilling)
as
required by the EU Taxonomy.
Likely aligned.

37 The Taxonomy is referring to Appendix E in the Taxonomy Annex 1.

38 Directive 2000/60/EC of the European Parliament and of the Council of 23 October 2000 establishing a framework for Community action in the field of water policy

39 DIRECTIVE 2011/92/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the assessment of the effects of certain public and private projects on the environment.

40 Refer to the European List of Waste established by Commission Decision 2000/532/EC

efficient (with reference to ISO 20887241),
adaptable, flexible and
dismantlable to enable reuse and recycling.
Pollution
prevention and
control

Building components and materials used in the construction
comply with the criteria set out in Appendix C to the Taxonomy
Annex 1.

For building components and materials used in the construction
that may come into contact with occupiers, formaldehyde
emissions are within relevant limits42.

Where the new construction is located on
a potentially
contaminated site (brownfield site), the site has been subject to an
investigation for potential contaminants43.

Measures are taken to reduce noise, dust and pollutant emissions
during construction or maintenance works.
Information provided
by the issuer

The bank provides better loan terms
for
commercial real estate certified BREEAM
Excellent/Outstanding. According to the bank's
dialogue with the Norwegian Green Building
Council (Grønn Byggallianse) it is envisaged that
revised BREEAM Excellent criteria will be fully
aligned with the EU taxonomy technical criteria.

For all new loans to commercial real estate
projects, the bank currently asks a specific
question on risks related to contaminated ground
and other relevant forms of pollution.
As BREEAM-certification is not a requirement, the
bank cannot guarantee that the requirements related to
pollution prevention and control
will be met
for
buildings not certified.
Likely partly aligned.
Protection and
restoration of
biodiversity and
ecosystems

An Environmental Impact Assessment (EIA) or screening should
be
completed in accordance with the EU EIA-directive or national
provisions44.

Where an EIA has been carried out, the required mitigation and
compensation measures for protecting the environment are
implemented.

For sites/operations located in or near biodiversity-sensitive areas
(including the Natura 2000 network of protected areas, UNESCO
World Heritage sites and Key Biodiversity Areas, as well as other
protected areas), an appropriate assessment where applicable, has
been conducted and based on its conclusions the necessary
mitigation measures
are implemented.

The new construction
should not be
built on one of the following:
a)
arable land and crop land;
Relevant contextual information

Areas with prioritized biodiversity, endangered
species and protected areas are regulated in the
Nature Diversity Act.

Construction of buildings will normally not require
an EIA, as the area has already been made
available for new construction in the municipality
regulation plans.

The Planning and Building
Act is setting out
requirements to the municipality regulation plans,
to i.a. protect valuable land.
Information provided by the issuer
The bank's credit handbook will prohibit loans to

activities in wetlands and biodiversity sensitive
areas ("verneområder").
Likely aligned.

41 ISO 20887:2020, Sustainability in buildings and civil engineering works - Design for disassembly and adaptability - Principles, requirements and guidance (version of [adoption date]: https://www.iso.org/standard/69370.html).

42 Emit less than 0,06 mg of formaldehyde per m³ of material or component and less than 0,001 mg of categories 1A and 1B carcinogenic volatile organic compounds per m³ of material or component, upon testing in accordance with CEN/TS 16516522 and ISO 16000-3 523 or other comparable standardised test conditions and determination method.

43 Standard ISO 18400 can be used.

44 The Taxonomy is referring to Appendix D in the Taxonomy Annex 1.

b)
c)
greenfield land of recognised high biodiversity value and land
that serves as habitat of endangered species (flora and fauna)
listed on the European Red List or the IUCN Red List.
land matching the definition of forest as set out in national law
used in the national greenhouse gas inventory, or where not
available, is in accordance with the FAO definition of forest45.

For all new loans to commercial real estate
projects, the bank currently asks a specific
question on risks related to the protection of
biodiversity.
---------- --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- --------------------------------------------------------------------------------------------------------------------------------------------------------------------- --

45 Land spanning more than 0,5 hectares with trees higher than five meters and a canopy cover of more than 10 %, or trees able to reach those thresholds in situ. It does not include land that is predominantly under agricultural or urban land use, FAO Global Resources Assessment 2020. Terms and definitions.(version of [adoption date]: http://www.fao.org/3/I8661EN/i8661en.pdf).

Renovation of existing buildings

Framework
activity
Green buildings
Taxonomy
activity
Renovation of existing buildings (NACE code F41 and F43)
EU Technical mitigation criteria Comments on alignment CICERO Green's
comments on alignment
Technical
screening
criteria
Renovation of existing buildings, eligible if:

The reduction of primary energy demand (PED)
must be at least 30 %.
Information provided by the issuer
The following eligibility criteria apply:

Costs related to renovations leading to a reduction in primary energy
demand of at least 30%.
For
the full building to qualify, it should after renovations be

expected to meet the criteria above for buildings built either before
or after 2021.
Likely aligned.
EU Taxonomy DNSH-criteria Comments on alignment Alignment
Climate change
adaptation
Please see under Construction of new buildings.
Sustainable use
and protection of
water and marine
resources
Please see under Construction of new buildings.
Transition to a
circular economy
Please s under Construction of buildings.
Pollution
prevention and
control

Building components and materials used in the
construction comply with the criteria set out in
Appendix C to the Taxonomy Annex 1.

For building components and materials used in
renovation
that may come into contact with
occupiers, formaldehyde emissions are within
relevant limits46.

Measures are taken to reduce noise, dust and
pollutant emissions during construction or
maintenance works.
Information provided by the issuer

The bank provides better loan terms
for commercial real estate
certified BREEAM Excellent/Outstanding. This will also apply to
BREEAM-In-Use. According to the bank's dialogue with the
Norwegian Green Building Council (Grønn Byggallianse) it is
envisaged that revised BREEAM Excellent criteria will be fully
aligned with the EU taxonomy technical criteria.

It is envisaged that advisors will assess loans according to the
taxonomy criteria, including the circular economy criteria, via a
dedicated interface of the loan assessment module used today.
As BREEAM-certification is not a requirement, the bank cannot
guarantee that the requirements related to pollution prevention and control
will be met for buildings not certified.
Likely partly aligned.

46 Emit less than 0,06 mg of formaldehyde per m³ of material or component and less than 0,001 mg of categories 1A and 1B carcinogenic volatile organic compounds per m³ of material or component, upon testing in accordance with CEN/TS 16516522 and ISO 16000-3 523 or other comparable standardised test conditions and determination method.

Protection and N/A N/A N/A
restoration of
biodiversity and
ecosystems

Acquisition and ownership of buildings

Framework
activity
Green buildings
Taxonomy
activity
Acquisition and ownership of buildings (NACE L68)
EU Technical mitigation criteria Comments on alignment CICERO Green's
comments on
alignment
Technical
screening criteria

Buying real estate and exercising ownership of that real
estate.
Information provided by the issuer
The following eligibility criteria apply:
Likely aligned
Acquisition and ownership of buildings are eligible if:
1.
For buildings built before 31 December 2020, the
building has at least an Energy Performance Certificate
(EPC) class A. As an alternative, the building is within
the top 15% of the national or regional building stock
expressed as operational Primary Energy Demand (PED)
and demonstrated by adequate evidence, which at least
compares the performance of the relevant asset to the
performance of the national or regional stock built before
31 December 2020 and at least distinguishes between
residential and non-residential buildings.
2.
For buildings built after 31 December 2020, the building
meets the criteria specified in Section 7.1 of this Annex
that are relevant at the time of the acquisition.
3.
Where the building is a large non-residential building
(with an effective rated output for heating systems,
systems for combined space heating and ventilation, air
conditioning systems or systems for combined air
conditioning and ventilation of over 290 kW) it is
efficiently operated through energy performance
monitoring and assessment.
Buildings built before 2021

Energy Performance Certificate A, or

buildings within the top 15% of the national or regional stock in
terms of primary energy demand, defined as

buildings built according to Norwegian building codes of
2010 (TEK10) or 2017 (TEK17) (to ensure TEK10-
alignment, we use a conservative 2-year time lag and include
buildings built from 2012 and onwards, for hotels and
restaurants we use a 3-year time lag), or

for buildings built prior to 2012, Energy Performance
Certificate B.

Commercial buildings with BREEAM-NOR Excellent certificate or
better, and minimum 6 credits in the BREEAM-NOR "Energy"
category.
For large, non-residential buildings (with an effective rated output for
heating systems, systems for combined space heating and ventilation,
air-conditioning systems or systems for combined air-conditioning
and ventilation of over 290 kW) it is efficiently operated through
energy performance monitoring and assessment.
EU Taxonomy DNSH-criteria Comments on alignment Alignment
Climate change
adaptation
Please see under Construction of new buildings.
Sustainable use
and protection of
water and marine
resources
N/A N/A N/A
Transition to a
circular economy
N/A N/A N/A
Pollution N/A N/A N/A
prevention and
control
Protection and N/A N/A N/A
restoration of
biodiversity and
ecosystems

Appendix 3: About CICERO Shades of Green

CICERO Green is a subsidiary of the climate research institute CICERO. CICERO is Norway's foremost institute for interdisciplinary climate research. We deliver new insight that helps solve the climate challenge and strengthen international cooperation. CICERO has garnered attention for its work on the effects of manmade emissions on the climate and has played an active role in the UN's IPCC since 1995. CICERO staff provide quality control and methodological development for CICERO Green.

CICERO Green provides second opinions on institutions' frameworks and guidance for assessing and selecting eligible projects for green bond investments. CICERO Green is internationally recognized as a leading provider of independent reviews of green bonds, since the market's inception in 2008. CICERO Green is independent of the entity issuing the bond, its directors, senior management and advisers, and is remunerated in a way that prevents any conflicts of interests arising as a result of the fee structure. CICERO Green operates independently from the financial sector and other stakeholders to preserve the unbiased nature and high quality of second opinions.

We work with both international and domestic issuers, drawing on the global expertise of the Expert Network on Second Opinions (ENSO). Led by CICERO Green, ENSO contributes expertise to the second opinions, and is comprised of a network of trusted, independent research institutions and reputable experts on climate change and other environmental issues, including the Basque Center for Climate Change (BC3), the Stockholm Environment Institute, the Institute of Energy, Environment and Economy at Tsinghua University, the International Institute for Sustainable Development (IISD) and the School for Environment and Sustainability (SEAS) at the University of Michigan.

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