EUROPEAN SUSTAINABLE FINANCE DISCLOSURE REGULATION
(Regulation (EU) 2019/2088 – SFDR)
A. Sustainability Risks
029 Capital (“029”) considers sustainability risks as part of its investment decision-making process where and to the extent deemed relevant. Sustainability risks refer to environmental, social or governance events or conditions that could have an actual or potential material adverse effect on the value of an investment.
The assessment of sustainability risks is conducted as part of the due diligence process prior to entering into any investment or transaction. 029 retains full discretion to refrain from investing or to proceed with an investment despite identified sustainability risks. In such cases, 029 may, at its discretion, apply measures to mitigate or manage such risks where considered appropriate.
029 applies the principle of proportionality when assessing sustainability risks, taking into account the strategic relevance of the investment, its size, complexity and transactional context.
B. Principal Adverse Impacts
No consideration of principal adverse impacts on sustainability factors
029 does not currently consider the principal adverse impacts of investment decisions on sustainability factors within the meaning of Regulation (EU) 2019/2088. Sustainability factors include, inter alia, environmental, social and employee matters, respect for human rights and anti-corruption and anti-bribery matters.
At present, no sustainability indicators are applied. 029 considers that the administrative and operational burden associated with the systematic consideration of principal adverse impacts would be disproportionate in light of the nature, scale and scope of its activities and investment approach.
029 operates as a privately held investment office pursuing selective, opportunistic investments across private market situations. The application and interpretation of the SFDR and related Regulatory Technical Standards (“RTS”) remain subject to ongoing regulatory development and legal uncertainty. 029 will monitor regulatory developments and may reassess its approach if and when a practicable market standard and administrative practice is established.
C. Sustainability-related Product Disclosures
Summary
029 integrates certain environmental, social and governance considerations into its investment process by applying sector-based exclusions. These exclusions are assessed on a pre-investment and post-investment basis through an approach considered proportionate and appropriate in light of the organizational structure and investment strategy of 029.
No sustainable investment objective
Sustainable investment, within the meaning of Regulation (EU) 2019/2088, is not an objective of 029.
Environmental or social characteristics
029 does not invest in, provide financing to, or otherwise support, directly or indirectly, entities whose primary business activities include:
- Tobacco
- Alcohol
- Weapons and ammunition
- Gambling
- Pornography
Investment Strategy
029 pursues a flexible, opportunistic investment strategy across private market situations. Investments may include minority or majority positions and may span various stages and sectors. Investment decisions are driven by conviction, structure and strategic alignment rather than predefined asset allocation targets.
Proportion of Investments
029 does not commit to investing a fixed proportion of its capital in investments aligned with environmental or social characteristics. Investments are made exclusively in accordance with its investment strategy. No portion of capital is allocated to other asset classes outside this scope.
Monitoring of Environmental or Social Characteristics
029 monitors compliance with the above-listed exclusion criteria prior to investment and, where applicable, following investment. Post-investment monitoring is conducted through ongoing, largely informal communication with relevant counterparties. No regular formal ESG assessments are performed.
Methodologies
Methodologies currently applied consist of information obtained during the due diligence process prior to investment and through regular communication following an investment. No quantitative ESG metrics or sustainability indicators are currently used.
Data Sources and Processing
Information is primarily obtained through direct interaction with counterparties and portfolio companies. No additional systematic third-party ESG data sources are regularly utilized.
Limitations to Methodologies and Data
Information collected during due diligence is externally verified only where misrepresentation is suspected. As a result, it cannot be entirely excluded that inaccurate information remains undetected in certain cases. Given the long-term and relationship-based nature of its investments, 029 places significant emphasis on trust and ongoing engagement as mitigating factors.
Due Diligence
The assessment of environmental and social characteristics, limited to the exclusion criteria outlined above, forms part of the due diligence process. Beyond this, no comprehensive ESG assessment is conducted unless deemed appropriate on an ad hoc basis, taking into account the size, strategic importance and transactional context of the investment.
Engagement Policies
Where potential issues related to the exclusion criteria are identified, 029 may engage with relevant counterparties with the objective of addressing such issues, provided that such engagement is considered proportionate and appropriate in light of the size and strategic importance of the investment and the respective bargaining positions.