Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainable-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”).
Sustainability Risks (Art. 3 SFDR)
btov Partners S.à r.l. II and btov Partners S.à r.l. VI, (“btov”) considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment. btov considers sustainability risks as part of the due diligence process prior to any investment. This also includes an assessment of sustainability risks. The results of such assessment are taken into account when the investment decision is being taken. However, btov remains free in its decision to refrain from investing or to invest despite sustainability risks in which case btov can also apply measures to reduce or mitigate any sustainability risks. At all times, btov will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.
Principle adverse sustainability impact statement (Article 4 SFDR)
Art. 4 SFDR provides for a framework aimed at achieving transparency with regard to any principle adverse impacts of investment decisions on sustainability factors as defined in the SFDR.
While btov acknowledges the importance of incorporating ESG principles into its core processes and throughout the investment, ownership, and exit phases, btov does not yet take into account any principle adverse impact of its investment decisions on sustainability factors as specified in the SFDR. btov believes that the information provided to them by the portfolio companies is not yet sufficient to allow them to do so.
Moreover, given that the Sustainable Finance Disclosure Regulation (EU 2019/2088) (“SFDR“) and the accompanying Regulatory Technical Standards (“RTS“) are new legislative acts, there is very little or no practical experience or practice with regard to applying their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions to the strategies pursued by btov. If and to the extent that these uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, btov will reevaluate following them in due course.
Remuneration Disclosure (Article 5 SFDR)
As a registered AIFM within the meaning of section 2(4) of the KAGB, btov does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. The integration of sustainability risks is not considered with respect to the determination of the remuneration.