SFDR Website Disclosures

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”).


Policy for integration of  sustainability risks in investment decision-making process (art 3 of 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.

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.

However it  does not mean that Alfabeat’s activities were not conducted by the principles and values guiding corporate social responsibility, and investments were devoid of aspects taking into account environmental as well as developmental issues. EU-funded grant programs were implemented through the Fund, and consequently, the Fund’s investment process took into account a number of investment restrictions, some of which were partially the ESG factors. For example, such investment restrictions included investments in investment projects and sectors with significant reputational risks, as well as in entities that may be engaged in activities that are considered illegal or ethically controversial, such as, for example:

  • production or trading related to: weapons, tobacco products, alcoholic beverages or drugs,
  • production or placing on the market pornographic content;
  • games of chance, betting, slot machine games and low-win machine games,
  • coal mining,
  • steel production.


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.


Consistency of remuneration polices in the relation to the integration of sustainability risks (art. 5 of 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.