365 Capital Management B.V. (“365 Capital”) makes the following disclosures in accordance with articles 3(1), 4 (1) (b) and 5(1) of the Disclosure Regulation.
Integration of sustainability risks
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”.
For 365 Capital, sustainability risks are risks which, if they were to occur, would cause a material adverse impact on the value of companies in its portfolio. Consideration of sustainability risk does not imply that a fund has a sustainable investment objective, but rather describes how sustainability risk is considered as part of the overall investment process. Before any investment decision is made on behalf of a fund that 365 Capital manages, an investment decision process is followed. As part of the investment decision process 365 Capital assess the risks attached to a potential investment opportunity, which includes sustainability risks.
At 365 Capital, we believe that adherence to ESG (Environmental, Social, Governance) principles is essential to doing good business. Our main objective is to generate an attractive return for our investors while also creating value for the businesses, as well as society and the planet. We aim to invest in companies that demonstrate responsible business practices, adhere to sound governance structure, and comply with social and ecological requirements. We monitor and engage with our portfolio companies during our ownership period with the aim to consistently improve ESG performance.
365 Capital pays staff a combination of fixed remuneration and variable remuneration. Variable remuneration for relevant staff considers compliance with all policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process.
No consideration of adverse impacts of investment decisions on sustainability factors
In accordance with article 4 sub 1 (b) of the Disclosure Regulation, 365 Capital states that it does not consider adverse impacts of investment decisions on all sustainability factors as outlined 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 Disclosure Regulation. Given the relatively small size of the organization and short operating history of 365 Capital, the disclosure as set forth in article 4 sub 1 (a) of the Disclosure Regulation is not currently proportional.
Nevertheless, 365 Capital will continue to engage with the currently available sustainability data from all portfolios with the aim to identify any adverse sustainably risks and improve ESG performance on best-effort basis. 365 Capital will review its position on a regular basis to account for regulatory evolution and will consider reporting on the criterion once consistent required data is available.