Information disclosed under Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”).
Sustainability risks means an environmental, social or governance event or condition (risks to ESG factors, environmental, social or corporate governance risks) that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. Such risks may materialize with respect to various sustainability factors, particularly with respect to climate change or other adverse environmental effects, as well as in the area of social, employee matters or human rights, or in connection with the occurrence of bribery or corruption matters.
The SFDR regulates making of sustainability disclosures by, among others, financial market participants. Alfabeat Alfa Spółka z ograniczoną odpowiedzialnością (“Alfabeat”) as manager of Alfabeat Alfa Spółka z ograniczoną odpowiedzialnością ASI S.K.A. (“Fund”) is classified as such financial market participant.
Strategy for integration of sustainability risks in investment decision-making process (art 3 of SFDR).
The Fund’s investment period, when investment decisions were made, covered the years 2017 – 2019. No investment decisions were made after this period, and currently the Fund is in the disinvestment phase. Accordingly, Alfabeat with respect to the Fund did not and does not take into account sustainability risks in its investment decision-making process. As a result, Alfabeat has not adopted a strategy for the Fund to incorporate sustainability risks into its operations.
Investment decisions do not consider principal adverse impacts on sustainable factors: transparency on adverse effects on sustainable development (art. 4 of SFDR).
Alfabeat states that it does not consider the main adverse effects of its investment decisions on sustainability factors. This is due to the fact that investment decisions with respect to the Fund were made by Alfabeat before the SFDR requirements came into force. Furthermore, given that the Fund is in a divestment period, Alfabeat does not intend to take into account the main adverse effects of its investment decisions on sustainability factors in the future. This is due to the fact that the Fund’s investment strategy and policy has focused on areas of investment such as health, ageing, highly efficient processing of goods and the use of IT for social development in the aforementioned areas, while ensuring the diversification of the Fund’s portfolio, so individual exit decisions in respect of the Fund are not likely to generate adverse sustainability impacts.
Consistency of remuneration polices in the relation to the integration of sustainability risks. (art. 5 of the SFDR)
Given that Alfabeat is not obliged to have a strategy for introducing ESG risks into the business activities in its investment decision-making process, consequently Alfabeat does not ensure the consistency of its remuneration policies with the introduction of sustainability risks into the business. However, remuneration matters at Alfabeat reflects the level of knowledge and experience of the associates and are not driven by non-merit factors.