Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector as amended (“SFDR”)
The SFDR forms part of the European Commission’s action plan on sustainable finance and imposes new transparency obligations and periodic reporting requirements on financial market participants (including authorized and registered managers of alternative investment fund managers (AIFM) at both product and entity level.
As a financial market participant, Neulogy Ventures S.à r.l as general partner and registered alternative investment fund manager of Slovak Venture Fund S.C.A., SICAR (the “SICAR”) makes the following disclosure in accordance with SFDR.
The investments of the SICAR do not take into account the EU criteria for environmentally sustainable economic activities.
Integration of Sustainability Risks
Sustainability risks, being environmental, social or governance events or conditions that, if they occur, could cause a negative material impact on the value of the investments, are considered by Neulogy Ventures S.à r.l in its investment decision-making processes and due diligence procedures. These processes will be monitored by the risk management function of the AIFM.
Neulogy Ventures S.à r.l implements appropriate risk measurements, processes and techniques to ensure that the risks including the sustainability risks are adequately documented and monitors said risk in respect of each of the target portfolio companies of the registered AIF managed. Moreover, certain sectors are completely excluded from investment on environmental, social or governance grounds. The risk management policy of Neulogy Ventures S.à r.l identifies sustainability risks as one of those categories of risk to be monitored in the investment and due diligence process.
No Consideration of Sustainability Adverse Impacts
In relation to the consideration of principal adverse impacts, Neulogy Ventures S.à r.l notes that there are still a number of uncertainties regarding this obligation, in particular because the relevant regulatory technical standards have not yet been published in final form by the European authorities. In addition, given the size of Neulogy Ventures S.à r.l. and the SICAR, the necessary resources are not available to acquire the data to comply with the future requirements in this regard.
Therefore, while supportive of the policy aims of the principal adverse impact regime, Neulogy Ventures S.à r.l does not currently consider principal adverse impacts. This decision will be kept under review pending the publication of the final regulatory technical standards and further details will be provided in due course.
Neulogy Ventures S.à r.l is remunerated by means of a management fee, payable by certain compartments in the SICAR, calculated on either the subscription commitments (during the investment period) or on the invested capital and is subject to a cap. Such mechanism does not encourage excessive risk taking and is thus consistent with the integration of sustainability risks into the investment decision-making process. Affiliates of Neulogy Ventures S.à r.l. are entitled to receive a special return which is dependent on the financial returns of certain of the compartments in the SICAR. The risk management process in place regarding the investment decision-making process ensures that excessive risk is not encouraged (including as regards sustainability risks).