SFDR disclosure
“Sustainability Related Disclosures”
Nucleo Ventures B.V (the AIFM), a Dutch-based registered alternative investment fund manager within the meaning of article 3(2)(b) of Directive 2011/61/EU of 8 June 2011 on alternative investment fund managers (AIFMD), makes the following disclosures for the purposes of Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (SFDR) and Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (the Taxonomy Regulation). As clarified by the European Commission in its Q&As on sustainability-related disclosures published on 14 July 2021, the AIFM must comply with certain SFDR requirements applicable to registered alternative investment fund managers.
The AIFM acts as registered alternative investment fund manager of Nucleo Ventures Coöperatief U.A. (the Fund).
The Fund qualifies under article 6 of the SFDR as it does not promote environmental or social characteristics (article 8 of the SFDR) nor does it have sustainable investments as its objective (article 9 of the SFDR).
AIFM-related disclosures
Transparency of sustainability risk policies and transparency of the integration of sustainability risks - article 3(1) and article 6 of the SFDR
General overview
A sustainability risk refers to an environmental, social or governance (ESG) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.
The AIFM does not integrate sustainability risks in its investment decision-making process for the following reasons:
- the investment due diligence and investment monitoring tools used by the AIFM to calculate risk and returns of the Fund do not take into account such risks but mainly economic and financial risks;
- in view of the AIFM size it is not intended to change the investment decision-making process of the AIFM to integrate such sustainability risks as this will be too costly and not relevant with respect to the Fund.
No consideration of adverse impacts of investment decisions on sustainability factors - article 4(1)(b) of the SFDR
Article 4(1) of the SFDR requires fund managers such as the AIFM to provide a clear statement as to whether or not they consider the "adverse impacts" of investment decisions on sustainability factors, e.g. environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
Although ESG and sustainability risks are important to the AIFM, the latter does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by article 4(1) of the SFDR, in particular due to the fact that:
- no reliable and sufficiently available or accessible data is available to perform such impact measurement.
- the underlying investments are not generally required to report on such factors in the manner prescribed by SFDR.
The AIFM does not intend to consider adverse impacts of investment decisions on sustainability factors in the near future as a mandatory investment decision criteria.
Transparency of remuneration policies in relation to the integration of sustainability risks - article 5(1) of the SFDR
For the purposes of article 5(1) of the SFDR, the AIFM declares that it has not put in place a remuneration policy in light of the fact that it qualifies as a registered alternative investment fund manager and thus does not fall under the requirement to uphold a remuneration policy required for licensed AIFMS under the AIFMD.