Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainable-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”)
equation Management GmbH (“EQUATION”) is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (the “SFDR”).
EQUATION considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment. EQUATION considers sustainability risks as part of the due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted using a due diligence questionnaire. The results of such assessment are taken into account on a non-binding basis when the investment decision is being taken. At all times, EQUATION will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.
EQUATION does not consider adverse impacts of investment decisions on sustainability factors. Sustainability factors are environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery. Given EQUATION’s fund-of-funds investment strategy, EQUATION will not have direct access to the target funds’ portfolio companies. Therefore, EQUATION will not have access to the information required for the principal adverse impact disclosures pursuant to Art. 4 (1) lit. a) SFDR and the accompanying Regulatory Technical Standards (RTS).
As a registered alternative investment fund manager pursuant to KAGB, the Manager does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.
EQUATION amended the above SFDR disclosures in line with their current policies and market practice.