The investment vehicle of the European Super Angels Club
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The wording below constitutes Venionaire Ventures S.à r.l.‘s disclosures in accordance with the EU Sustainable Finance Disclosure Regulation (2019/2088) („SFDR“) when acting as a manager under the AIFMD.
- Sustainability risks
This section constitutes our disclosure in accordance with Article 3(1) of the SFDR.
The policy on the integration of sustainability risks in our investment decision making process can be found in our ESG Policy ( “How Venionaire incorporates ESG in the analysis of companies”).
- No consideration of adverse impacts of investment decisions on sustainability factors, and no consideration of adverse impact of investment advice on sustainability factors
This section constitutes our disclosure in accordance with Article 4 (1b) of the SFDR.
The SFDR requires us to make a “comply or explain” decision whether to consider the principal adverse impacts (“PAIs”) of investment decisions on sustainability factors in our investment advice or our investment decision-making processes, in accordance with a specific regime as outlined in SFDR. We have decided not to comply with the SFDR regime. We are therefore required to publish and maintain on our website a statement to explain our reasons for not complying with the PAI regime in SFDR, and information as to whether and when we intend to comply with such regime.
We have carefully evaluated the requirements of the PAI regime in Article 4 SFDR, and in the draft Regulatory Technical Standards which were published in February 2021 (the “PAI regime”).
We are supportive of the policy aims of the PAI regime, to improve transparency to clients, investors and the market, as to how financial market participants and financial advisers integrate consideration of the adverse impacts of investment decisions on sustainability factors. However, taking account of the nature and scale of our activities and the types of products we make available, we consider that it would be disproportionate to comply with the specific regime in the SFDR.
We will keep our decision not to comply with the PAI regime under regular review, and will formally re-evaluate the decision from time to time.
Notwithstanding our decision not to comply with the PAI regime, we wish to re-affirm our overall commitment to environment, social and governance (“ESG”) matters. In our ESG-Policy, we summarise the positive ESG-related initiatives and policies adopted by us. For the avoidance of doubt, none of the following information is intended to suggest that we comply with the PAI regime.
Despite the above, we continue to advocate ESG reporting and aims to further strengthen the data input from the underlying issuers. We seek an active dialogue with relevant stakeholders to encourage them to improve their own ESG approach, including on reporting, and to consider adopting generally accepted standards.
- Integration of sustainability risks in remuneration policy
This section constitutes our disclosure in accordance with Article 5 (1) of the SFDR.
Our remuneration program is designed to align the interests of our staff, investors, and clients and aims to compensate professional and support staff fairly, appropriately, and objectively.
We have linked our fixed and variable remuneration to a proof of compliance with the existing policies. References to compliance with the ESG policy and sustainability risks are part of our assessment criteria when reviewing the performance of our staff.