Sustainability-related disclosures
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This is an English translation provided for convenience. In case of any discrepancy, the Polish version prevails.
Introduction
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 (also referred to as “SFDR” or the “SFDR Regulation”) lays down harmonised rules for financial market participants and financial advisers on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes, and the provision of sustainability-related information with respect to financial products.
Under the SFDR, Prometeia Innovation Fund ASI sp. z o.o. (also referred to as “PIF”, the “Company”, “ASI” / “ZASI”) is considered a financial market participant, as it is an internally managed alternative investment company.
In accordance with the position (the “KNF position”) of the Office of the Polish Financial Supervision Authority (the “KNF”), which takes into account the position presented by the European Commission (the “EC”) in response to a query from the Joint Committee of the European Supervisory Authorities – EBA, ESMA and EIOPA, where the provisions of the SFDR, in terms of the obligations imposed, refer to provisions of the AIFM Directive applicable only to AIF managers operating under an authorisation (e.g. Article 6(3) in conjunction with Article 6(1), Article 11(2) of the SFDR), “AIF managers operating on the basis of registration should apply those provisions by analogy and, for example, include that information in pre-contractual disclosures to investors and in periodic information provided to investors, taking into account applicable national law” (the “EC position”).
In view of the above, and given that the Company operates on the basis of an entry in the register maintained by the KNF, some provisions of the SFDR will be applied by analogy, in accordance with the EC position and the KNF position.
Policy on the integration of sustainability risks (Article 3 of the SFDR)
The Company declares that, in the course of its business, it has not adopted a policy on the integration of sustainability risks, including policies on taking such risks into account. This means that the Company does not take those risks into account in its current operations. The statement that the Company does not have a policy on the integration of sustainability risks should be understood to mean that the Company has not prepared, at the level of its entire organisation, policies setting out how environmental, social or governance events or conditions are taken into account which, if they occur, could have an actual or potential material negative impact on the value of an investment.
The Company believes that sustainability risk does not currently have a significant impact on the performance of the financial product (i.e. the ASI). This assessment was made taking into account various factors, such as the characteristics of the financial products offered by the Company, the expected size and direction of the ASI’s activities in the near future, the investment selection criteria applied in the ASI’s investment policy and strategy, the principles of portfolio diversification and the variety of sectors in which the ASI seeks potential investments.
Accordingly, the Company does not intend to adopt a policy on the integration of sustainability risks in the near future. The Company monitors the impact of these risks on its business on an ongoing basis and, should their impact on returns from participation in the ASI increase, will take appropriate steps to inform investors.
Approach to considering principal adverse impacts of investment decisions on sustainability factors (Article 4 of the SFDR)
The Company declares that it does not consider the adverse impacts of investment decisions on sustainability factors, owing to the specific nature of its investment activities, the nature of its investments and the limited availability of sustainability indicators.
The manner in which material negative impacts on sustainability aspects are assessed and taken into account may change – consequently, this statement may be amended in the future. In particular, the Company expects that, over time, it will gradually expand the range of available data that are key to taking into account the principal adverse impacts on sustainability factors in the investment decision-making process.
The Company justifies its decision by the scale of the ASI’s activities and its assumptions as to the course of the investment process. In the Company’s view, given the current size of the ASI’s activities, considering the principal adverse impacts of investment decisions on sustainability factors would significantly increase the costs of the investment process, which, given the nature of the ASI, the type of products offered and the scale of its operations, could reduce the ASI’s profitability.
Consistency of the remuneration policy with the integration of sustainability risks (Article 5 of the SFDR)
The Company declares that it does not currently ensure consistency of its remuneration policy with the integration of sustainability risks.
Disclosure of the assessment of the likely impacts of sustainability risks on investment returns (Article 6 of the SFDR) and of the approach to considering principal adverse impacts of investment decisions on sustainability factors (Article 7(2) of the SFDR)
The Company has concluded that sustainability risks are not material, as the likelihood of their occurrence is low and the assessment of environmental, social or governance conditions for a given investment is positive or indicates that those risks are being effectively mitigated.
Accordingly, in an annex to the investment strategy, which will be disclosed to every new investor before joining the ASI, the Company will provide information describing:
- how sustainability risks are integrated into the Company’s investment decisions; and
- the results of the assessment of the likely impacts of sustainability risks on the returns of the financial products it makes available (i.e. the ASI).
As the Company does not consider the principal adverse impacts of investment decisions on sustainability factors at the level of its organisation, it will also disclose this fact in the annex to the investment strategy, which will be disclosed to every new investor before joining the ASI. The disclosure will take the form of a statement that, in respect of the ASI, the Company does not consider the principal adverse impacts of investment decisions on sustainability factors, together with an explanation of the reasons.
The Company also states that investments within the financial product do not take into account the EU criteria for environmentally sustainable economic activities (Article 7 of the Taxonomy Regulation, Article 6(1) and (3) and Article 11(1) and (2) of the SFDR). The Company does not offer financial products promoting environmental or social characteristics, or financial products that have sustainable investment as their objective.
Final provisions
In accordance with Article 12 of the SFDR, the Company ensures that all information published pursuant to Articles 3, 5 and 10 of the SFDR is kept up to date and, accordingly, periodically verifies whether updates are required. Should the information need to be changed, the Company will publish an explanation of such changes on its website.
