Introduction/Sustainability Risk
On March 10, 2021, an EU Regulation came into force requiring AIFM ´light´ managers, such as Beherend Vennoot “De Koepel” B.V. (the Manager), to provide information on sustainability in their investment decisions. This regulation, the Sustainable Finance Disclosure Regulation (SFDR), requires the Manager to provide information on how sustainability risks (as defined below) are integrated into the investment decision-making process.
For the Manager, a sustainability risk means “an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment”.
Article 3/Investment decision procedure
Before any investment decisions are made on behalf of Open de Koepel C.V., the Manager performs general confirmatory due diligence which covers financial, legal, fiscal and environmental issues, and is performed by external advisors when necessary. The Manager considers environmental, social and governance to be standard subjects covered during the due diligence process. The advisory committee of the Manager aims to assess the identified risks alongside other relevant factors set out in an investment proposal. Following its assessment, the advisory committee of the Manager makes investment decisions having regard to the investment policy, investment objectives and identified sustainability risks.
Article 4 sub 2/Reporting adverse impact
The Manager is required to disclose information on whether, in accordance with the SFDR, it “considers the effects of investment decisions (…) that result in adverse effects on sustainability factors” (the “main adverse effects”). The Manager does not consider adverse impacts of investment decisions on sustainability factors. This is because the Manager is not currently able to obtain and/or measure all of the data from all of its investment strategies that it is required to report to clients and investors under the SFDR, or to do so systematically, consistently and at a reasonable cost. Considering the small size of the Manager, the disclosure set forth in article 4 sub 1, would be disproportional. Therefore the Manager takes advantage of the exemption (under Article 4(1)(b)) for AIFMDs with fewer than 500 employees.
Article 5/ Remuneration policy
The Manager’s remuneration policy aims to ensure that the interests of employees are aligned with the interests of investors in Open de Koepel C.V., avoiding as far as possible incentives that could result in excessive risk-taking behaviour. The remuneration policy is divided in a combination of fixed remuneration and variable remuneration. Variable remuneration for relevant staff takes into account compliance with all policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process.
The Manager does not manage funds which fall under article 8 or 9 SFDR, and therefore article 10 SFDR is not applicable.