FRC2 GP Sarl (the “Fund Manager”) makes the following disclosure in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”) and the Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (“Taxonomy”).
INTEGRATION OF SUSTAINABILITY RISKS INTO THE FUND MANAGER’S INVESTMENT DECISION MAKING PROCESS
The SFDR, article 2(22), defines sustainability risk as “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment”, below “ESG factors”. The SFDR does not define more specifically what is meant by “material” in this context.
As part of the investment process for a potential fund investment, an initial externally conducted assessment of ESG-factors including human & labour rights, ethics, environmental & governance factors is carried out through a detailed questionnaire and interviews. This assessment grades all potential investments as positive, neutral and negative with regard to their impact on the environment, social and governance matters. The Fund Manager rejects any potential investments that are negative.
SUSTAINABILITY RISKS’ EFFECT ON THE RETURNS OF THE FUND INVESTMENTS
In the Fund Manager’s view, sustainability risks, particularly where unmitigated, could affect the value of investments held by a fund and/or the ability of the fund to dispose of investments, and hence the value of the fund. However, given the very early stage of the investments the fund(s) managed by the Fund Manager these risks are assessed these to be minor compared to the overall risks associated with the investments made by the fund. However, as the portfolio matures this assessment may change and the Fund Manager periodically reviews the impact of sustainability risks on the portfolio.
NO CONSIDERATION OF PRINCIPAL ADVERSE IMPACTS (“PAI”) OF INVESTMENT DECISIONS ON SUSTAINABILITY FACTORS
Currently, the Fund Manager does not consider adverse impacts of investment decisions on sustainability factors as specifically set out in the SFDR. The Fund Manager has chosen not to do so for the present time as it considers that its existing ESG policies and procedures are appropriate, proportional and tailored to the investment strategy of the funds it manages. In addition, the Fund Manager considers that the data that can reasonably be obtained from its portfolio companies is not meaningful enough to render a PAI analysis meaningful. The Fund Manager monitors regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations. The Fund Manager will periodically review whether its existing policies and procedures are appropriate, and where required or otherwise advisable, evaluate whether to consider such adverse impacts.
The Fund Manager has a total remuneration model consistent with the good governance of the fund(s) under its management, to the extent that this sustainability is a factor in the operations of the individuals of the Fund Manager this is reflected in the remuneration policy.