Organization Nordea Investment Management North America, Inc. (“NIMNAI”), based in New York City, was established in 1994 and is organized as a corporation under the laws of Delaware. Prior to November 2001, NIMNAI was known as Unibank Investment Management. NIMNAI registered with the SEC as an investment adviser on November 20, 2001. NIMNAI is currently registered with the U.S. Securities and Exchange Commission as a Registered Investment Adviser. As used in this Brochure, the words “we,” “our,” and “us” refer to NIMNAI and the words “you,” “your,” and “client” refer to you as either a current or prospective client of NIMNAI. NIMNAI is a direct, wholly-owned subsidiary of Nordea Investment Management AB (“NIM AB”). NIM AB is domiciled in Sweden and supervised primarily by the Swedish Financial Supervisory Authority. NIM AB is wholly-owned by Nordea Asset Management Holding AB (“NAM AB”). NAM AB is wholly-owned by Nordea Bank Abp. Nordea Bank Abp, the ultimate parent company bank of NIMNAI, is a publicly traded Finnish company and listed on the NASDAQ Nordic Exchange in Helsinki, Stockholm, and Copenhagen. As of December 31, 2023, NIMNAI manages approximately $0.884 billion of client assets on a discretionary basis. We do not currently manage any client assets on a non-discretionary basis, although we may do so in the future. Advisory Services We provide discretionary portfolio management and investment advisory services to several client types, including:
• separately managed accounts for institutional clients; and
• registered investment companies as to which NIMNAI is a sub-adviser. Additional detail about each of these client types is provided in Item 7, Types of Clients, below. We offer a broad range of investment strategies to meet the diverse requirements of our client’s investment needs. The strategies include fundamental and quantitative equities, fixed income and multi-asset strategies. Each strategy is managed by its dedicated investment boutique, respectively within its investment unit: Equities, Fixed Income or Multi-Assets. Equities: Fundamental Equities We offer several strategies from our Fundamental Equities boutique. These include but are not limited to:
• Emerging Stars Equity
• North American Stars Equity
• European Stars Equity
• Asian Stars Equity NIMNAI – Form ADV Part 2A Page 6 of 39
• Global Stars Equity
• Global Climate & Environment
• Global Social Empowerment
• Global Disruption
• Global Impact
• Global Climate Engagement
• Sustainable Environment and Biodiversity strategies
• Global Climate Focus
• Emerging Stars ex China Equity
• Global Social Solution Our investment management services in these strategies generally

relate to long-term investments in both listed and over-the-counter equity securities. These strategies do not generally invest in derivatives or similar financial instruments. However, from time to time, we utilize derivatives and other financial instruments. Additionally, these strategies can invest in emerging markets depending upon the investment restrictions agreed upon with the client. Fixed Income: European Covered Bond Our Fixed Income Rates boutique manages the European Covered Bond strategy. The strategy aims to provide clients with investment growth over the medium to long-term. The strategy mainly invests in European Covered Bonds and may use derivatives for hedging (reducing risks), efficient portfolio management and to seek investment gains. Multi-Assets Our Multi-Assets boutique manages a variety of products based on quantitative strategies. Our primary strategies from this boutique are:
• Stable Emerging Markets Equity
• Stable Global Equity
• Alpha Solutions (Alpha 7, 10, 15 MA)
• Balanced Income
• Flexible Fixed Income
• Stable Return Diversified Growth
• Global & Emerging Markets Equities Beta+
• Global, North America & Emerging Markets Responsible Equities Beta+
• Global Diversity Engagement Our investment management services in each of these strategies generally relate to long-term and short-term investments in exchange-listed securities, over-the-counter securities, foreign equity securities, corporate debt securities, U.S. government securities, option contracts on securities and commodities, futures contracts on equity indices and interest rates, contracts for differences, total return swaps, long and short positions in baskets of equities or bond issues with common characteristics, credit default swaps, pooled investment vehicles, and money market instruments. We may also utilize other financial instruments and derivatives. Other Investment Products NIMNAI – Form ADV Part 2A Page 7 of 39 We offer a variety of other investment products. For purposes of this Brochure, we have highlighted above the main products that are actively marketed to North American clients. However, during our discussions with clients and prospective clients, we may become aware of a situation where another product may be more suited to that client or prospective client’s specific needs. In that case, we may discuss other investment products with such client or prospective client, as appropriate, to see if there is a better fit between that client’s or prospective client’s needs and what we can offer. Wrap Fee Programs NIMNAI does not currently participate in wrap fee programs. In the past, we have participated in wrap fee programs and may decide to do so again in the future. NIMNAI – Form ADV Part 2A Page 8 of 39