Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainable-related disclosures in the financial services sector (EU) 2019/2088.
Athos Capital, SGEIC, S.A., Athos Capital Fund II, FCR Pyme and Athos Capital Investment, SCR Pyme, S.A. (hereinafter, “Athos”) are subject to the Regulation of the European Parliament and of the Council on sustainable-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”).
Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)
Athos considers sustainability risks as part of its investment decision-making process.
Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment.
Athos considers sustainability risks as part of the due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted using a checklist.
The results of such assessment are taken into account when the investment decision is being taken.
Athos remains free in its decision to refrain from investing or to invest despite sustainability risks in which case Athos can also apply measures to reduce or mitigate any sustainability risks.
At all times, Athos will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.
To enhance transparency and inform end investors, the policies on the integration of these risks, as required by Article 3 of the SFDR, are included in the ESG Policy.
Principle adverse sustainability impact statement (Article 4 SFDR)
According to Whereas (20) of the SFDR, a principle adverse sustainability impact shall be understood as “those impacts of investment decisions and advice that result in negative effects on sustainability factors” (be they environmental or social).
Athos pursues a venture capital strategy and invests mainly in companies within the digital economy sector.
Given that there are rarely adverse impacts on sustainability factors within digital economy Athos does not formally consider adverse impacts of investment decisions on sustainability. However, should there occur adverse impacts during the investment process, Athos will evaluate those adverse impacts and in case of a negative outcome will refrain from an investment.
Additionally, it shall be noted that, given that the SFDR is a new legislative act, and the accompanying Regulatory Technical Standards (“RTS“) is still a draft law, there is very little or no practical experience or practice with regard to applying their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions to the strategies pursued by Athos.
If and to the extent that these uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, Athos will re-evaluate following them in due course.
Transparency of remuneration policies in relation to the integration of sustainability risk (Article 5 SFDR)
As a registered SGEIC within the meaning of article 5.4 of Spanish Law 22/2014, Athos does not have the obligation to publish the remuneration policy on its website.
In any case, the remuneration policy adopted by Athos integrates the sustainability risks as one of its main pillars.