Impact

In order to comply with the sustainable finance disclosure regulation (SFDR), INKEF Capital B.V. (INKEF) makes the following disclosures.

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".

Before any investment decisions are made on behalf of a fund that INKEF manages, INKEF follows a structured investment decision-making process. This process includes, inter alia, an initial screening of potential investments against the fund’s investment strategy and binding investment criteria, a commercial and financial assessment, legal and tech due diligence, and, if applicable, a sustainability-related due diligence.

The sustainability-related due diligence assesses relevant environmental, social and governance (“ESG”) factors that are considered material for the relevant portfolio company, taking into account the nature, stage of development and sector of the business. Where relevant, identified sustainability risks and opportunities are discussed as part of the investment decision-making process and, if appropriate, reflected in investment conditions, governance arrangements or post-investment engagement. The final investment decision is taken in accordance with INKEF’s internal governance procedures, including review and approval by the investment committee.

INKEF views ESG as a standard topic in the pre-investment process. Part of the investment decisions process is that INKEF assesses the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are considered by INKEF when making investment decisions.

In addition, INKEF pays staff a combination of fixed remuneration and variable remuneration (including a possible bonus). Variable remuneration for relevant staff also takes into account compliance with all policies and procedures which are in effect within INKEF, including those relating to taking into account sustainability risks on the investment decision making process.

Employees are made aware of the applicable policies and procedures when starting their employment with INKEF.

No consideration of sustainability adverse impacts

In accordance with article 4 sub 1 (b) of the SFDR, INKEF states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the SFDR.

At this stage INKEF does not consider the adverse impacts of its investment decisions on sustainability factors, (i) because INKEF could not reasonably gather and/or measure all the relevant data of the portfolio companies of INKEF, taking into account reasonable cost for clients and investors and (ii) due to the small size of the organisation of INKEF, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden in connection therewith would not be proportional.

INKEF continues to closely monitor the market developments (including the level of availability of the data) as well as the regulatory developments. INKEF will at least on an annual basis review whether and when to comply with article 4 sub 1 (a) of the SFDR.