Sustainability risks (Article 3 of SFDR Regulation)

ALEA CAPITAL PARTNERS, SCR, S.A. is a venture capital company and is covered by Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of sustainability information in the financial services sector (the “SFDR Regulation”)”), which established a set of harmonised transparency rules for the financial services sector, including an obligation for financial market participants to publish and update on their websites a set of sustainability-related information in their investment decision-making processes. A ALEA CAPITAL PARTNERS, SCR, S.A.  it is not covered by the criteria of Article 4(3) and (4) of the SFDR Regulation which define the largest institutions.

According to the SFDR Regulation, “sustainability factors” are considered to be “environmental, social and labour issues, respect for human rights, the fight against corruption and bribery”, “sustainability risks”  means events or conditions of an  environmental, social or governance nature the occurrence of which is likely to cause an actual or potential significant negative impact on the value of the investment, and “sustainable investments” means investments in an economic activity that contributes to an environmental objective, as measured, for example, by key indicators of resource efficiency in terms of energy use, renewable energy, raw materials, water and soil, waste generation and greenhouse gas emissions,  or the impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequalities or that promotes social cohesion, social integration and industrial relations, or an investment in human capital or in economically or socially disadvantaged communities,  provided that such investments do not significantly impair any of those objectives and provided that the undertakings benefiting from the investment employ good governance practices, in particular with regard to management structures, industrial relations and sound staff remuneration practices and compliance with tax obligations.

ALEA CAPITAL PARTNERS, SCR, S.A. is governed by high ethical standards and its conduct is based on certain principles, including responsible investment, recognizing that environmental and/or social risks at the level of investments made by the funds under its management may affect its activity and the profitability of these investments. The various risks that may be relevant to the investments of the funds managed, including, in an ancillary manner, sustainability risks, are therefore considered on a case-by-case basis and in compliance with the mandates given under the management regulations of the funds under management, considering, to the extent that the respective management mandates so permit,  the development by the entities they participate in of appropriate and sustainability-oriented practices and principles.

For the purposes of Article 10 of the SFDR Regulation, it is clarified that ALEA CAPITAL PARTNERS, SCR, S.A. does not currently market or manage venture capital funds that promote, among others, environmental or social characteristics or a combination of these characteristics (provided for in Article 8 of the SFDR Regulation), nor venture capital funds that aim at sustainable investments (provided for in Article 9 of the SFDR Regulation),  However, it is not excluded that such characteristics and objectives may be achieved indirectly in compliance with the investment policies provided for in the management regulations of the venture capital funds it manages.

Non-consideration of the negative impacts of investment decisions on sustainability factors (Article 4 of the SFDR Regulation and article 12 of SFDR Delegated Regulation)

ALEA CAPITAL PARTNERS, SCR, S.A., without prejudice to its diligent and judicious performance, does not currently consider the negative impacts of investment decisions on sustainability factors, since the type of entities forming part of the funds managed by them at this date does not have sufficient and/or satisfactory sustainability information, in particular on the indicators listed in Annex I to Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 (the “SFDR Delegated Regulation”, supplementing the SFDR Regulation in this regard), and it is therefore not possible to obtain such information with resources proportionate to the size of those investee entities and the ALEA CAPITAL PARTNERS, SCR, S.A.

Thus, for the purposes of paragraph 1 of article 4 of the SFDR Regulation and article 12 of SFDR Delegated Regulation, ALEA CAPITAL PARTNERS, SCR, S.A. understands that it should not at present ensure the consideration of the negative impacts of investment decisions on sustainability factors in a systematic matter.

Without prejudice to the above, this is a matter that, due to its relevance, is under review and is periodically reassessed by ALEA CAPITAL PARTNERS, SCR, S.A., taking into account, inter alia, the indicators listed in Table 1 of Annex I to Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022.

Remuneration Policy (Article 5 of SFDR Regulation)

The remuneration policy in force at ALEA CAPITAL PARTNERS, SCR, S.A. does not currently integrate sustainability risks, so no information is disclosed to that extent, without prejudice to this being a matter under continuous review.

This statement has been updated on 10th May 2024. ALEA CAPITAL PARTNERS SCR, S.A. ensures that the information disclosed in accordance with articles 3. and 5. of the SFDR Regulation are kept up to date at all times, as required by article 12. of the SFDR Regulation.