Disclosures on the integration of sustainability risks in investment decision process and on the consideration of principal adverse impacts of investment decisions on sustainability factors
This statement is the consolidated statement on the handling of sustainability risks and on the principal adverse impacts of investment decisions on sustainability factors for High-Tech Gründerfonds GmbH & Co. KG, High-Tech Gründerfonds II GmbH & Co. KG and for High-Tech Gründerfonds III GmbH & Co. KG (hereinafter “High-Tech Gründerfonds”).
High-Tech Gründerfonds partially consider sustainability risks as part of the risk analysis in the investment decision-making process. High-Tech Gründerfonds have decided to improve, develop a systematic ESG policy and implement an ESG management system. The work is in progress.
Pursuant to Article 4 of the Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosure requirements in the financial services sector), the High-Tech Gründerfonds as fund managers are obliged to provide information on the consideration of principal adverse impacts of investment decisions on sustainability factors, i.e. principal adverse impacts in particular on environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters (so-called “Principal Adverse Impacts”/”PAI”).
Consideration of PAI largely depends on the availability of relevant information on the market. In the area of financing start-ups, the data required is often not available to a sufficient extent and in the required quality. However, High-Tech Gründerfonds take into account the impact of investments on several of the sustainability factors and exclude some investments that would affect environmental, social, ethical or governance factors. The nature and scope of the consideration is related to the specifics of the venture capital business (investments in start-ups). High-Tech Gründerfonds apply the principle of proportionality.
Due to the legislative procedures that have not yet been completed, there are subsequently still a large number of unresolved detailed questions with regard to the specific requirements for measuring and reporting PAI. High-Tech Gründerfonds therefore currently do not yet systematically take into account principle adverse impacts of investment decisions on sustainability factors and will first await further legal developments. Corresponding processes will hence only be implemented at a later date. High-Tech Gründerfonds will publish further information on their policies on the identification and prioritisation of principal adverse sustainability impacts and indicators as well as on measures taken or planned in this regard.
In this context, High-Tech Gründerfonds will assess possible compliance with codecies for responsible investments and internationally recognised standards, as well as the degree of compliance with the aims of the Paris Agreement, where applicable.
Information on the integration of sustainability risks as part of the remuneration policy
The remuneration policies of High-Tech Gründerfonds are consistent with the integration of sustainability risks from the environmental, social and corporate governance areas. The background to this is that High-Tech Gründerfonds only work with such public and private investors and only invest in start-ups that meet high standards in terms of social and governance criteria. In addition, High-Tech Gründerfonds also invest specifically in start-ups that pursue an environmentally friendly business model or even directly combat environmental pollution (for example, traceless materials GmbH). The revenue of the High-Tech Gründerfonds, from which in turn the remuneration is paid, are generated in compliance with this sustainability-related investment strategy, which is why the remuneration policy is already consistent with the integration of sustainability risks from the areas of environment, social and governance.