Sustainable Finance Disclosure
Date: 03.03.2023
Fund: KCV Fund Coöperatief U.A.
Manager: ACT Venture Partners Coöperatief U.A.
Status: Registered Alternative Investment Fund Manager under AIFMD
This disclosure is made in accordance with:
1. Definitions
Sustainable Investment means an investment in an economic activity that contributes to an environmental objective — such as the efficient use of energy, renewable energy sources, raw materials, water, land use, waste reduction, greenhouse gas emissions, biodiversity, and circular economy solutions — or an investment in an economic activity that contributes to a social objective — in particular tackling inequality, fostering social cohesion, social integration, labour relations, human capital and economically or socially disadvantaged communities — provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices.
Environmental Objective has the meaning assigned to it in Article 9 of the Taxonomy Regulation.
Sustainability Risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment(s).
Sustainability Factors mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
2. SFDR Classification
The SFDR identifies three regulatory regimes for financial products:
The KCV Fund qualifies as a "grey fund" under Article 6 of the SFDR. The Fund does not promote environmental or social characteristics (Article 8) and does not have sustainable investment as its objective (Article 9).
3. Manager-Related Disclosures
Sustainability Risk Assessment Process
The Manager integrates sustainability risk review into its investment procedures. This includes:
The Responsible Investment Policy operationalises this framework and is available separately.
Principal Adverse Impacts
The Manager does not consider principal adverse impacts of investment decisions on sustainability factors. This is due to:
There is no intention to implement such consideration in the foreseeable future.
Remuneration Policy
The Manager does not have a remuneration policy requirement under the applicable AIFMD provisions.
4. Fund-Related Disclosures
The underlying investments of the KCV Fund do not take into account the EU criteria for environmentally sustainable economic activities under the Taxonomy Regulation.
Fund: KCV Fund Coöperatief U.A.
Manager: ACT Venture Partners Coöperatief U.A.
Status: Registered Alternative Investment Fund Manager under AIFMD
This disclosure is made in accordance with:
- Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector ("SFDR")
- Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment ("Taxonomy Regulation")
1. Definitions
Sustainable Investment means an investment in an economic activity that contributes to an environmental objective — such as the efficient use of energy, renewable energy sources, raw materials, water, land use, waste reduction, greenhouse gas emissions, biodiversity, and circular economy solutions — or an investment in an economic activity that contributes to a social objective — in particular tackling inequality, fostering social cohesion, social integration, labour relations, human capital and economically or socially disadvantaged communities — provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices.
Environmental Objective has the meaning assigned to it in Article 9 of the Taxonomy Regulation.
Sustainability Risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment(s).
Sustainability Factors mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
2. SFDR Classification
The SFDR identifies three regulatory regimes for financial products:
- Grey Regime (Article 6): Products that do not promote environmental or social characteristics and do not have sustainable investment as their objective.
- Light Green Regime (Article 8): Products that promote environmental or social characteristics.
- Dark Green Regime (Article 9): Products that have sustainable investments as their objective.
The KCV Fund qualifies as a "grey fund" under Article 6 of the SFDR. The Fund does not promote environmental or social characteristics (Article 8) and does not have sustainable investment as its objective (Article 9).
3. Manager-Related Disclosures
Sustainability Risk Assessment Process
The Manager integrates sustainability risk review into its investment procedures. This includes:
- Pre-investment identification of material sustainability risks
- Incorporation of identified risks into overall investment proposals
- Assessment aligned with the Fund's investment policy and Investment Committee approval process
The Responsible Investment Policy operationalises this framework and is available separately.
Principal Adverse Impacts
The Manager does not consider principal adverse impacts of investment decisions on sustainability factors. This is due to:
- Insufficient availability of reliable data
- The investment strategy does not have a specific ESG focus
- Portfolio companies do not have the required sustainability reporting in place
There is no intention to implement such consideration in the foreseeable future.
Remuneration Policy
The Manager does not have a remuneration policy requirement under the applicable AIFMD provisions.
4. Fund-Related Disclosures
The underlying investments of the KCV Fund do not take into account the EU criteria for environmentally sustainable economic activities under the Taxonomy Regulation.