SFDR Statement
Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”):
I. Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)
Motu Ventures Management GmbH (the “Motu Ventures AIFM”) follows a code of conduct (including exclusion criteria with respect to a potential portfolio company’s business activities that are not eligible for investment) that is integrated in the investment processes. ESG factors are also part of every due diligence process, however, sustainability risks are not a separate part of the investment decision-making processes of Motu Ventures AIFM.
II. Principle adverse sustainability impact statement (Article 4 SFDR)
Art. 4 SFDR provides for a framework aimed at achieving transparency with regard to any principle adverse impacts of investment decisions on sustainability factors as defined in the SFDR. For this purpose, financial market participants such as the Motu Ventures AIFM must disclose certain information (in the future, taking into account the Regulatory Technical Standards (RTS)). Currently, the Motu Ventures AIFM believe that the information provided to them by the portfolio companies in relation to the investments is not yet sufficient (in particular with a view to the future RTS) to allow them to do so. Accordingly, it must be assumed that Motu Ventures AIFM does not yet take into account any principle adverse impact of investment decisions on sustainability factors as specified in the SFDR. However, Motu Ventures AIFM will monitor developments with regard to available information and consider whether it is reasonably possible in the future to disclose the information required by the Art. 4 SFDR-framework (including the future RTS).
III. Mandatory disclosures of remuneration policies in relation to the integration of sustainability risks (Article 5 SFDR)
As a registered AIFM within the meaning of section 2(6) of the KAGB and the EuVECA-Regulation, Motu Ventures AIFM does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. The integration of sustainability risks is not considered with respect to the determination of the remuneration.