Sustainability Policy

In accordance with the SFDR and the Taxonomy Regulation, the manager, as a manager of investment funds, must provide information on sustainability regarding the managed funds. This section provides the required information regarding the participations.

Qualification of the Participations

The Fund does not promote ecological or social characteristics ("light green investments" as referred to in Article 8 of the SFDR) and does not aim for sustainable investment ("dark green investments" as referred to in Article 9 of the SFDR). The underlying investments of this financial product do not consider the EU criteria for ecologically sustainable economic activities.

Policy on Sustainability Risks

The manager acknowledges that the realization of sustainability risks could potentially have a negative effect on the value of the investment. A sustainability risk, in short, is an event in the ecological, social, or governance domain (ESG domain) that can have a negative effect on the value of the participations. For example, sustainability risks in the ecological domain involve CO2 emissions, energy consumption, and biodiversity loss. Social sustainability risks might involve product liabilities and respect for human rights. In terms of governance and sustainability risks, one might consider inclusivity and diversity, compensation, and corporate ethics. The manager integrates sustainability risks to a limited extent into investment decisions.

Adverse Effects of Investment Decisions on Sustainability Factors Not Considered

The manager does not consider the adverse effects of investment decisions on sustainability factors and, therefore, does not prepare an annual so-called principal adverse sustainability impact assessment (SIA). Considering the adverse effects of investment decisions on sustainability factors would require the manager to report on these matters. The necessary information to report on this is currently unavailable within the manager. To obtain such information, the manager would need to take (costly) measures. This is considered disproportionate by the manager, at least at this moment. This is further underscored by the expectation that investors are unlikely to value a SIA. However, this does not preclude the manager from reconsidering the decision not to consider the adverse effects of investment decisions on sustainability factors if relevant circumstances arise. For example, if the majority of investors request a SIA.

Sustainability Risks and the Remuneration Policy

Under the AIFMD registration regime, the manager is not required to implement the legally prescribed remuneration policy. Given the limited size of the organization, it was decided not to (voluntarily) establish a specific remuneration policy. Due to the lack of (a requirement to develop) a remuneration policy, the SFDR's requirement regarding the provision of information on the remuneration policy and how it aligns with sustainability risks does not apply to the manager.