ESG Disclosures in accordance with SFDR
Last revised on December 6th 2024
As an EU based alternative investment fund manager, Hummingbird Ventures Management NV (“we”, “us” or “Hummingbird”) is subject to the Sustainable Finance Disclosure Regulation no. 2019/2088 (“SFDR”). The SFDR requires us to publish certain information on our website in respect of environmental, social and governance matters as set out below.
1. No consideration of adverse impacts of investment decisions on sustainability factors
Hummingbird does not formally consider the adverse impacts of its investment decisions on the sustainability factors referred to in article 4, §1, (b) of the SFDR. This means that Hummingbird’s investment decisions do not formally take into consideration the adverse impacts on sustainability, climate and other environment-related indicators (including, greenhouse gas emissions, biodiversity, water and waste) or on other social and governance-related indicators such as employee matters, human rights, anti-corruption and anti-bribery.
Hummingbird is of the view that in the investment field in which it is active, being early stage companies, it is difficult to reliantly measure and quantify the different adverse impacts and sustainability factors as referred to in the SFDR or that such would take disproportional resources. Even if this would be feasible, for many investments this information would, due to the limited operations of most early-stage companies, probably be of very limited relevance and might in some cases even generate faulty investor expectations in the field of ESG.
Hummingbird may re-evaluate its position not to formally consider the adverse impacts of its investment decision on the sustainability factors under the SFDR, but such is not expected in the near future.
2. Integration of sustainability risks in the investment process of Hummingbird
In its investment process, Hummingbird does take sustainability risks as well as their probability into consideration. This means that Hummingbird does consider potential environmental, social or governance events or conditions which, if and when they were to occur, could have an actual or potential material negative impact on the value of the relevant investment. During the due diligence and ongoing-monitoring process in respect of its (potential) investments, Hummingbird reviews a broad range of sustainability risks and their probability and presents them to the relevant investment committee for consideration.
3. Integration of sustainability risks into the Hummingbird remuneration policy
Hummingbird has established a remuneration policy which takes – indirectly through the risk profile and financial performance of its investments – into account the potential impact of sustainability risks on its investments. As with other identified risks, the remuneration policy of Hummingbird seeks to discourage excessive risk-taking in respect of sustainability risk.