Investment Policy
Bitcoin Holding Sweden AB
Updated by CEO: 2025-08-11
Effective until further notice

1.0 Purpose and Scope

1.1 Purpose
This investment policy establishes the governing guidelines for how Bitcoin Holding Sweden AB (“the Company”) shall manage investments and associated risks.

1.2 Objectives

• Protect and preserve the Company’s capital.

• Maximize long-term returns within the established risk level.

• Ensure a stable and sustainable operation over time.

• Maintain transparency towards shareholders and other stakeholders.

1.3 Scope
The policy applies to all investments, financial dispositions, and risk management measures. It is binding for the Board of Directors, the CEO, and other individuals with decision-making authority within the Company.

2.0 Definitions

• Net Asset Value (NAV): The total market value of all assets at a given time, including cash equivalents.

• Cash equivalents: Bank funds in SEK, USD, or EUR.

• Portfolio: The Company’s total investment assets.

• Debt ratio: Interest-bearing liabilities in relation to NAV.

• Leverage level: The percentage of the Company’s Bitcoin holdings that are pledged as collateral, expressed as a percentage.

3.0 Investment Strategy

3.1 Strategic Focus
The Company invests exclusively in Bitcoin as its core holding. This decision is based on the Board’s assessment that Bitcoin, according to long-term analysis, offers an attractive combination of value preservation and value appreciation.

3.2 Diversification Parameters

• Bitcoin: A maximum of 95% of NAV may be invested in Bitcoin.

• Cash equivalents: A minimum of 5% of NAV must be held in cash equivalents (SEK, USD, or EUR).

• No exposure is permitted to fiat currencies other than SEK, USD, or EUR, or to other asset classes, unless unanimously approved by the Board.

3.3 Investment Horizon
10–20 years.

3.4 Return Target
The Company aims for an average annual return of 29% through 2034, based on the Company’s analysis of Bitcoin’s long-term price development. The target may be revised following new analysis. After 2034, a new return target will be set based on prevailing market conditions, with the objective of outperforming established inflation hedges (e.g., gold and real estate).

4.0 Financial Risk

4.1 Liquidity Strategy

• A minimum of 5% of NAV shall be held in cash equivalents (SEK, USD, or EUR).

• The liquidity buffer shall be monitored at least quarterly and replenished as needed.

4.2 Leverage Policy

• Maximum leverage is 50% of the Company’s Bitcoin holdings.

• Borrowing is only permitted at strategic times and following Board approval.

4.3 Credit Risk
Investments with counterparties may only be made if they have documented and satisfactory creditworthiness.

4.4 Currency Risk
The Company may only be exposed to SEK, USD, or EUR. Exposure to USD or EUR exceeding 20% of NAV must be analyzed and may be hedged if necessary.

5.0 Political and Geopolitical Risk

5.1 Definition
The risk that investments are negatively affected by changes in politics, legislation, or global conflicts.

5.2 Approach
The Company prioritizes operations and investments in jurisdictions with stable economies, strong legal frameworks, and low political risk.

5.3 Bitcoin-Specific Market Surveillance

• Ongoing monitoring of legislation and regulation regarding cryptocurrencies in relevant countries.

• Analysis of global initiatives for Central Bank Digital Currencies (CBDCs) and their potential impact on the Bitcoin market.

6.0 Business Ethics Risk

6.1 Ethical Guidelines

• The Company shall adhere to high ethical standards in all investments and business relationships.

• Investments linked to illegal activities, money laundering, or corruption are strictly prohibited.

6.2 Sustainability
Environmental, Social, and Governance (ESG) factors shall be considered in all major investment decisions.

7.0 Legal Risk

7.1 Regulatory Compliance

• All agreements and investments must undergo legal review prior to execution.

• When raising capital, the Company shall comply with applicable legislation and the Prospectus Regulation.

7.2 Tax Risk
Tax regulations shall be analyzed to ensure proper and tax-efficient management of investments and transactions.

8.0 Cyber and Information Security Risk

8.1 Custody of Cryptocurrencies

• All Bitcoin holdings shall be stored in multi-signature cold storage and/or MPC solutions with a trusted party.

• Only a limited portion of capital may be kept in hot storage for operational needs.

8.2 Security Procedures

• Regular security audits shall be performed to safeguard the Company’s systems and assets.

• A continuity and recovery plan shall be in place and updated at least annually.

9.0 Key Personnel and Succession Risk

9.1 Incentives
Key personnel shall be offered incentive programs to promote long-term commitment.

9.2 Succession Planning

• A documented plan shall exist for replacing key personnel.

• Strategic decisions and processes shall be documented to ensure continuity.

10.0 Risk Monitoring and Reporting

10.1 Responsibility
The Board of Directors is responsible for continuously monitoring the Company’s risk exposure and following up on the investment strategy.

10.2 Reporting
Reports on risk exposure, returns, and significant changes in the portfolio shall be prepared and presented to shareholders at least once per year in connection with the annual report. This investment policy shall undergo annual review and be revised when necessary.

Jonas Livros
CEO – Bitcoin Holding Sweden AB