ESG

When making investment decisions, their adverse effects on sustainable development factors are not taken into account.

Information provided by the company
TEAMVEST sp. z o. o.
as an external managing company to

I TEAMVEST SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ ALTERNATYWKA SPÓŁKA INWESTYCYJNA SPÓŁKA KOMANDYTOWO – AKCYJNA

in fulfillment of the requirements arising from
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November
2019 on the disclosure of information related to sustainable development in the financial services sector (hereinafter referred to as the “SFDR Regulation”)

and

COMMISSION DELEGATED REGULATION (EU) 2022/1288 of 6 April 2022
supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying details on the content and presentation of information in relation to the ‘do no serious harm’ principle, specifying the content, methods and presentation of information in relation to sustainability indicators and adverse effects on sustainable development, as well as specifying the content and presentation of information in relation to the promotion of environmental or social aspects and objectives regarding sustainable investments in pre-contractual documents, websites and periodic reports (hereinafter referred to as the “SFDR Delegated Regulation”)

 I. Introduction
The SFDR establishes harmonized rules for financial market participants and financial advisors on transparency with regard to the introduction of sustainability risks into their activities and the consideration of adverse sustainability impacts in their activities, as well as with respect to their reporting of related information. with sustainable development on financial products.

The company TEAMVEST sp. z o. o. (hereinafter “ZASI”) falls within the scope of application of the SFDR Regulation as:

  • financial market participant because it is a manager of alternative investment companies (ZASI), i.e. under European law, a manager of alternative investment funds (AIFM);

The company: I TEAMVEST SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ ALTERNATYWKA SPÓŁKA INWESTYCYJNA SPÓŁKA KOMANDYTOWO – AKCYJNA (hereinafter referred to as “ASI”) is covered by the SFDR Regulation as:

  • financial product because it is an alternative investment company (ASI), i.e. under European law, an alternative investment fund (AIF).

Due to the fact that ZASI operates only on the basis of an entry in the register kept by the Polish Financial Supervision Authority (hereinafter referred to as the “KNF”), some of the provisions of the SFDR Regulation will be applied by analogy in accordance with the guidelines of the European Securities and Markets Authority and the positions of the Polish Financial Supervision Authority.
II. II. Transparency of sustainability risk strategies
(Article 3(1) SFDR)
The SFDR Regulation requires financial market participants to publish on their website information on their strategies for introducing sustainability risks into their activities in the investment decision-making process.In accordance with the Investment Strategy applicable at ASI (point V), ASI makes investment decisions based on its analyzes and market data. ASI may additionally use analyzes conducted by third parties. The research process is multi-faceted and concerns, among others, the aspect of risk for sustainable development, i.e. examining whether there is an environmental, social or management situation or conditions which, if they occur, could have an actual or potential significant negative impact on the value of the investment.
 III. Transparency on adverse sustainability impacts at the entity level (Article 4(1) and 7(2) of the SFDR Regulation)
The main unfavorable effects on sustainable development should be understood as those effects of investment decisions that have an unfavorable impact on sustainable development factors. “Sustainable development factors” include environmental, social and labor issues, respect for human rights and counteracting corruption and bribery.

In no case does ASI provide for taking into account the main unfavorable effects of investment decisions on sustainable development factors from the perspective of the investment’s impact on the environment, as this would significantly increase the costs of the investment process, which due to the nature of ASI, the type of products made available and the scale of the business conducted – would limit ASI’s profitability.
IV. Transparency of remuneration policies in connection with the introduction of sustainable development risks into the business (Article 5(1) SFDR)
Financial market participants include in their remuneration policies information on how to ensure consistency of these policies with the introduction of sustainable development risks into their activities and publish this information on their websites.

ZASI informs that it is not an entity obliged to adopt a remuneration policy, therefore the above requirement does not apply to it.

Pursuant to Art. 13 section 1 of Directive 2011/61/EU (hereinafter the “AIFM Directive“) – Member States require AIFM to have remuneration policies and practices; remuneration policies and practices must be consistent with and promote sound and effective risk management and must not encourage risk-taking that is inconsistent with the risk profiles, regulations or instruments of incorporation of the AIFs they manage.

ZASI is not obliged to apply the remuneration policy, because in accordance with Art. 3 section 2 of the AIFM Directive, the above provisions do not apply to AIFMs managing portfolios of AIFs where the total value of assets under management, including assets acquired through leverage, does not exceed the threshold of EUR 100 million in total; or does not exceed the threshold of EUR 500 million where the AIF’s portfolios consist of unleveraged AIFs and for which redemption rights cannot be exercised for a period of five years from the date of initial investment in each AIF.

Under Polish law, in accordance with Art. 70zb section 4 Act of 27 May 2004 on investment funds and management of alternative investment funds (Journal of Laws of 2022, item 1523, as amended). ZASI is also exempt from the obligation to develop and implement a remuneration policy.
V. Transparency regarding the introduction of sustainable development risks into the business (Article 6(1) SFDR)
Financial market participants include a description of the following elements in the information disclosed before concluding a contract:

  • how sustainability risks are incorporated into their investment decisions; and
  • the results of assessing the likely impact of sustainability risks on the returns of the financial products they provide.

Where financial market participants consider the sustainability risks to be non-significant, the description of the elements referred to in the first subparagraph shall include a clear and concise explanation of the reasons for considering those risks to be non-significant.

In its investment strategy, which is disclosed to every investor before joining ASI, ASI informs about the issues described above.

Due to the fact that:

  • ASI does not in any case provide for taking into account the main adverse effects of investment decisions on sustainable development factors;
  • The regulations of the SFDR Regulation apply only by analogy;

ASI will not provide investors with information prepared in accordance with Annex II to the SFDR Delegated Regulation.
VI. Transparency in promoting an environmental or social aspect in pre-contractual disclosures (Article 8, Article 9, Article 10(1) SFDR)
ZASI does not offer financial products that promote environmental or social aspects (or both) or aim at sustainable investments.
VII. Additonal information
1. ZASI ensures that all information published in accordance with Art. 3, 5 or 10 of the SFDR Regulation were updated on an ongoing basis. Where a financial market participant changes such information, it shall publish on the same website a clear explanation of such change (Article 12 of the SFDR).
2. COMMISSION DELEGATED REGULATION (EU) 2021/1255 of 21 April 2021 amending Delegated Regulation (EU) No 231/2013 as regards sustainability risks and sustainability factors that must be taken into account by managers of alternative investment funds has amended scope:

  • ZASI resources (Article 22 of Regulation 231/2013);
  • types of conflicts of interest (Article 30 of Regulation 231/2013);
  • risk management policy (Article 40 of Regulation 231/2013);
  • organizational requirements (Article 57 of Regulation 231/2013);
  • control (Article 60 of Regulation 231/2013).

The above changes will not apply to ZASI/ASI, because in accordance with Art. 3 section 2 of the AIFM Directive, the above provisions do not apply to AIFMs managing portfolios of AIFs where the total value of assets under management, including assets acquired through leverage, does not exceed the threshold of EUR 100 million in total; or does not exceed the threshold of EUR 500 million where the AIF’s portfolios consist of unleveraged AIFs and for which redemption rights cannot be exercised for a period of five years from the date of initial investment in each AIF.
3.

Declaration in accordance with Art. 7 REGULATION (EU) 2020/852 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 18 June 2020 on establishing a framework to facilitate sustainable investment, amending Regulation (EU) 2019/2088 (OJ EU.L.2020.198.13 of 2020.06 .22):

Investments under this financial product (ASI) do not take into account EU criteria for environmentally sustainable business activities.