Sector Gamma is a partner owned, independent asset manager spun out of Sector Asset Management in 2006. Our ambition is to add value through active and fundamentally based stock selection strategies. Sector Gamma consists of five investment professionals and the company manages two funds. Our market neutral hedge fund, Sector Healthcare Fund, was launched in 2005 and our long only UCITS fund, Sector Healthcare Value Fund, was launched in 2010. Our operations and Scandinavian investor relations efforts are outsourced to our long-term partner, Sector Asset Management. Our fund structure is based in Ireland and the company is authorized, by the Financial Supervisory Authority of Norway, as an investment firm.


Responsible Investments

As institutional investors, we have a duty to act in the best long-term interests of our beneficiaries. In this fiduciary role, we believe that environmental, social, and corporate governance (ESG) issues can affect the performance of our investment portfolios.

We aspire to comply with the United Nations Principles for Responsible Investment (UN PRI). By integrating the Principles in our investment process, we seek to achieve the best possible risk-adjusted returns for our beneficiaries as well as better align our investment activities with the broader interests of society.


Sustainability-related disclosures

As of 30 November 2022


In March 2021, the Sustainable Finance Disclosure Regulation (“SFDR”) came into effect. SFDR seeks to establish a pan-European framework to facilitate sustainable investment, by providing for a harmonised approach in respect of sustainability-related disclosures to investors within the European Union's financial services sector.

The scope of SFDR is extremely broad, covering a wide range of financial products and financial market participants. It seeks to achieve more transparency regarding how financial market participants integrate Sustainability Risks into their investment decisions and the consideration of adverse sustainability impacts into the investment process.

The objectives of SFDR are to

  • strengthen protection for investors of financial products,
  • improve the disclosures made available to investors from financial market participants and
  • improve the disclosures made available to investors regarding the financial products, to amongst other things, enable investors make informed investment decisions.

Under Article 3 and 4 of the SFDR, information must be published on the integration of sustainability risks into the investment decisions and on the considerations of the principal adverse impacts of the investment decisions on sustainability factors.

Integration of Sustainability Risks & ESG Factors (SFDR Article 3)

As an institutional investor, Sector Gamma has a duty to act in the long-term interests of its beneficiaries. In this fiduciary role, we believe that ESG issues can affect the performance of our investment portfolios.

We evaluate and integrates Sustainability Risks and other relevant ESG factors into our investment decision-making process in a bottom-up fashion with the support of dedicated ESG resources. Sustainability Risks and ESG factors are analysed and accounted for in our risk/reward framework for stock selection and portfolio construction.

More information about the integration of sustainability risks and ESG factors can be found in our ESG policy.

Consideration of Adverse Sustainability Impacts of Investment Decisions on Sustainability Factors (SFDR Article 4)

Even though Sector Gamma has integrated the consideration of Sustainability Risks into the investment decision-making process, we do not currently consider the principal adverse impacts of our investment decisions on Sustainability Factors. The reason for opting against doing so is primarily that Sector Gamma has a commercial preference to focus resources elsewhere.

We reserve the right to reconsider this position in the future when more information and guidance is available.

Remuneration Policy (SFDR Article 5)

Sector Gamma’s remuneration policy shall serve to promote sound management and control of Sector Gamma and its clients’ risks, including sustainability risks, and shall not encourage excessive risk taking on the part of employees (in all aspects of its activities that relate to the services which are subject to public authorisation).

An excerpt of Sector Gamma’s Remuneration Policy is set out below:

“The purpose of the Company's remuneration policy is to establish an arrangement for compensation that may help the Company to attract highly skilled and qualified employees, develop and retain key persons and encourage perpetuity and continuous progress to reach the Company’s goals, while at the same time ensuring the integrity of the Company’s risk management.

The remuneration policy determines the following:

(i) To which of the Company’s employees and representatives this remuneration policy shall be applicable, in accordance with the abovementioned regulations concerning the calculation and payment of remuneration (Identified Employees). Such employees are divided into (a) executive management, (b) employees with control functions, (c) representatives and (d) employees whose responsibilities are of significant importance to the Company's or clients’ risk exposure. Regarding the last category in (d) above, employees with similar remuneration as executive managers and other employees with tasks of considerable importance to the Company's or clients’ risk exposure will be considered separately;

(ii) Whether the Company has more than 50 employees or total of assets under management that exceeds EUR 1.25 billion (and thus required to establish a remuneration committee); and

(iii) Which frameworks and guidelines that will apply to the calculation and payment of both the fixed and variable remuneration to those defined as “Identified Employees”.

The remuneration from the Company to Identified Employees may consist of a fixed and a variable element. The fixed element shall be determined on an individual basis and be sufficiently high (so that the Identified Employees of the Company are not dependent on any relevant variable remuneration, enabling the Company to not disburse the variable part of the remuneration).

The Company has no guaranteed bonuses or sign-on fees.”

We note that the Company’s Identified Employees are the CEO and the Risk Manager.

Fund Classification

For the purposes of SFDR, all Funds managed by Sector Gamma AS qualify as Article 8 financial products.

For product-specific disclosures, please refer to the sub-pages of Sector Healthcare Fund and Sector Healthcare Value Fund.


This information is provided solely for the purposes of Sector Gamma’s compliance with the provisions of the SFDR. The information contained herein is subject to change at any time without notice. Subject to the legal structure of the relevant fund, any issue and allotment of shares in funds managed by Sector Gamma is subject to the provisions of the respective fund’s prospectus and the supplement thereto and any application for shares in such funds shall be based solely on the information contained in such documentation and the most recent annual and/or semi-annual report of the fund and shall be made pursuant to the terms of the respective application form.