SFDR Disclosures

​

In order to comply with the sustainable finance disclosure regulation (“SFDR”)¹, Global Cleantech Management B.V. (“GCC”) makes the following disclosures.

​

Integration of sustainability risks 

​

A sustainability risk means: ​"an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment". 

   

Before any investment decisions are made on behalf of a fund that GCC manages, an investment decision process is followed which includes a decision by the Investment Committee. GCC views ESG as a standard topic in the pre-investment process. Part of the investment decision process is that GCC assesses the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are considered by GCC when making investment decisions.

​

In addition, GCC pays staff a combination of fixed remuneration and variable remuneration (including a possible bonus). Variable remuneration for relevant staff also takes into account compliance with all policies and procedures which are in effect within GCC, including those relating to taking into account sustainability risks on the investment decision making process. 

​

Employees are made aware of the applicable policies and procedures when starting their employment with GCC. 

​

No consideration of sustainability adverse impacts 

​

In accordance with article 4 sub 1 (b) of the SFDR, GCC states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the SFDR. 

​

At this stage, GCC does not consider the adverse impacts of its investment decisions on sustainability factors, (i) because GCC could not reasonably gather and/or measure all the relevant data of the portfolio companies of GCC, taking into account reasonable cost for clients and investors and (ii) due to  the small size of the organisation of GCC, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden in connection therewith would not be proportional.

​

GCC continues to closely monitor the market developments (including the level of availability of the data) as well as the regulatory developments. GCC will at least on an annual basis review whether and when to comply with article 4 sub 1 (a) of the SFDR

 

¹Regulation (EU) 2019/2088

​

​