ESG Disclosures in accordance with SFDR
Last revised on 23rd of November 2023
In its capacity of alternative investment fund manager ('AIFM'), Hummingbird Ventures Management NV (the “Manager”) is subject to the disclosure obligations relating to environmental, social and governance (“ESG”) matters as set forth in:
- Regulation (EU) no. 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”);
- Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying the details of the content and presentation of the information in relation to the principle of ‘do no significant harm’, specifying the content, methodologies and presentation of information in relation to sustainability indicators and adverse sustainability impacts, and the content and presentation of the information in relation to the promotion of environmental or social characteristics and sustainable investment objectives in precontractual documents, on websites and in periodic reports (‘SFDR RTS’); and
- Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (‘Taxonomy Regulation’).
The Manager may update this information at any time, and will in such event publish a clarification on such amendment on this website.
1 No integration of sustainability risks
The Manager does not integrate sustainability risks into its investment decision-making process, as referred to in article 3 SFDR. In other words, (i) sustainability risks are not integrated into the Manager’s investment decisions and (ii) the likely impacts of sustainability risks on the returns of the funds managed by the Manager are not formally assessed.
The Manager acknowledges that ESG-related events or conditions could potentially have a (negative) impact on the value of the investments made on behalf of funds managed by the Manager. However, the Manager does not consider those adverse impacts as it is a small organisation with limited resources and personnel and is not capable of determining precisely what the sustainability risks of its investment decisions would be based on the different criteria set forth in the SFDR and the legislation implementing the SFDR.
In addition, the funds managed by the Manager invest, among others, in start-ups that, due to their size and limited resources, are not capable of providing the information required for that purpose. Consequently, the Manager is currently not in a position to formally integrate sustainability risks into its investment decisions, nor to formally assess the likely impacts of sustainability risks on the returns.
Hence, the investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.
2 No consideration of adverse sustainability impacts of investment decisions
The Manager does not consider any adverse impacts of its investment decisions on sustainability factors, as referred to in article 4, §1, (b) SFDR. This means that adverse impacts on sustainability, on climate and other environment-related indicators (including, greenhouse gas emissions, biodiversity, water and waste) or indicators for social and employee, respect for human rights, anti-corruption and anti-bribery matters are not formally taken into consideration in the Manager’s investment decisions.
In accordance with article 4, §1, (b) and article 7, §2 of the SFDR, the Manager does not consider the adverse impacts of its investment decisions on sustainability factors. The Manager does not consider those adverse impacts because it is a small organisation with limited resources and personnel and is not capable of determining precisely what the adverse impacts of its investment decisions would be based on the different criteria set forth in the SFDR and the legislation implementing the SFDR.
In addition, the funds managed by the Manager invest, among others, in start-ups that, due to their size and limited resources, are not capable of providing the information required for that purpose. The Manager does not intend to consider adverse impacts of investment decisions on sustainability factors in the future in accordance with article 4, §1, (a) of the SFDR for the aforementioned reasons.
3 Integration of sustainability risks into remuneration policies
The Manager has remuneration policies with respect to the remuneration of its directors and staff, as required by applicable legislation. However, given that the Manager does not formally integrate sustainability risks in its investment decisions and does not assess the likely impacts of sustainability risks on the returns of the funds managed by it, sustainability risks are not formally or directly integrated in the Manager’s remuneration policy either.