Mandatory disclosures under Regulation of the European Parliament and of the Council on Sustainability-Related Disclosures in the financial services sector (EU) 2019/2088 (“SFDR”)
Sustainability risks
Project A Ventures Management GmbH ("Project A", LEI: 3912008RQ3ORI32X9I23) integrates sustainability risks in its decision-making process, as referred to under Article 3 of the Sustainable Finance Disclosure Regulation (EU 2019/2088) (“SFDR”). Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material negative effect on the value of the investment.
The review of sustainability risks is part of the due diligence process and risk management by the Project A team.
Project A considers sustainability risks as part of the due diligence process by implementing an investment exclusion list and following a dedicated ESG Due Diligence checklist, covering topics such as:
The results of such assessment are integrated into the investment memorandum and evaluated when the investment decision is being taken. Should an issue be identified and if the investment has been, or is intended to be, undertaken despite material sustainability risks pursuant to the ESG Due Diligence, investment managers must ensure no unreasonable sustainability risks exist (a “red flag”), provide more details of their research and integrate it into the investment committee briefing. This briefing is then evaluated by the investment committee before a final decision on investment, assessing whether ESG risks are acceptable in light of details provided by research despite flagged sustainability risks.
Project A remains free in its decision to refrain from investing or to invest despite sustainability risks, in which case, Project A can also apply measures to reduce or mitigate them. At all times, Project A will apply the principle of proportionality considering the identified ESG issue, the strategic relevance of an investment and the potential to reduce and mitigate such risks.
No consideration of adverse impacts of investment decisions on sustainability factors
Currently, Project A does not consider principal adverse impacts (PAIs) on sustainability factors as described by Article 4 SFDR and the Commission Delegated Regulation (EU) 2022/1288 (“SFDR-DR”). Sustainability factors are environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
Given that Project A invests primarily in early-stage companies which have no regulatory disclosure requirements and little market experience reporting against ESG metrics, obtaining this data in full for compliance purposes remains practically unfulfillable at this time.
Project A is regularly reviewing its approach to PAIs, as well as the legal and administrative developments on the interpretation of the SFDR and SFDR-DR and might reevaluate its stance once smaller and younger companies report more ESG data.
Transparency of remuneration policies in relation to the integration of sustainability risks
The Capital Management Company (Kapitalverwaltungsgesellschaft) considers sustainability risks as part of its investment decision-making process, but not as part of its remuneration policy.
Sustainability-related disclosures
Information pursuant to Art. 10 of the Disclosure Regulation can be viewed following the respective fund links.
Date of Publication: 10 March 2021
The information on this website and accompanying Article 10 SFDR disclosures has been updated as follows,
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