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”):
I. Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)
HV Capital Manager GmbH (former HV Holtzbrinck Ventures Manager GmbH), HV Holtzbrinck Ventures Fund V GmbH & Co. KG und HV Holtzbrinck Ventures Co-Investment Fund I GmbH & Co. KG (the “HV Capital AIFM”) follow a code of conduct (including exclusion criteria with respect to a potential portfolio company’s business activities that are not eligible for investment) that is integrated in the investment processes. ESG factors are also part of every due diligence process, however, sustainability risks are not a separate part of the investment decision-making processes of the HV Capital AIFM.
II. Principle adverse sustainability impact statement (Article 4 SFDR)
Art. 4 SFDR provides for a framework aimed at achieving transparency with regard to any principle adverse impacts of investment decisions on sustainability factors as defined in the SFDR. For this purpose, financial market participants such as the HV Capital AIFM must disclose certain information (in the future, taking into account the Regulatory Technical Standards (RTS)). Currently, the HV Capital AIFM believe that the information provided to them by the portfolio companies in relation to the investments is not yet sufficient (in particular with a view to the future RTS) to allow them to do so. Accordingly, it must be assumed that the HV Capital AIFM do not yet take into account any principle adverse impact of investment decisions on sustainability factors as specified in the SFDR. However, the HV Capital AIFM will monitor developments with regard to available information and consider whether it is reasonably possible in the future to disclose the information required by the Art. 4 SFDR-framework (including the future RTS).
III. Mandatory disclosures of remuneration policies in relation to the integration of sustainability risks (Article 5 SFDR)
As a registered AIFM within the meaning of section 2(4) of the KAGB, the HV Capital AIFM do not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. The integration of sustainability risks is not considered with respect to the determination of the remuneration.