Sustainability Disclosures

Last updated: 28 November, 2023

Roundtable EuVECA Manager Lux does not consider the adverse impacts on its investment decisions on sustainability factors (see below)

1. General

Roundtable EuVECA Manager Lux S.à r.l. (the “Company” or the “EuVECA Manager” or “Roundtable”) is registered with the Commission de Surveillance du Secteur Financier (the “CSSF”) as a European venture capital funds manager in Luxembourg under Regulation (EU) No 345/2013 of the European Parliament and of the Council of 17 April 2013 on European venture capital funds (the “EuVECA Regulation”).

The Company is authorized to manage European qualifying venture capital funds (the “EuVECAs”).

The herein information is published pursuant to Articles 3(1), 4, and 5(1) of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures (“SFDR”) in the financial services sector.

The aim of SFDR is to increase the transparency of financial market participants towards end-investors and contribute to the objective of fighting green washing.

The SFDR focuses on the environmental and social impact of an entity’s investment decision.

Based on SFDR, the Company is classified as a “financial market participant”, and in accordance with Articles 3(1), 4, and 5(1) of SFDR, has to perform the following SFDR disclosures:

(a) provide information (i) about its policies on the integration of sustainability risks in their investment decision-making process (Article 3 (1) of SFDR) and (ii) on the consistency of its remuneration policy with the integration of sustainability risks (Article 5 (1) of SFDR) ; and

(b) provide clear reasons for why it does not consider adverse impacts of investment decisions on sustainability factors at entity level (Article 4 (1) (b) ofSFDR).

Those disclosures are being communicated hereinafter.

2. Transparency of Sustainability Risk Policy and Remuneration Policy (Art. 3 and 5 SFDR)

a. Risk Policy

According to article 3(1) of the SFDR, financial market participants (such as the Company) shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process.

Sustainability risks are environmental, social or governance uncertain event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of one or more investments held by an EuVECA managed by the Company.

The three factors of ESG can be described as follows:

Environment: It includes all risks associated with climate crisis, raw material depletion and environmental pollution.
Social: It covers all risks regarding diversity, human rights, consumer protection and animal welfare.
Governance: It refers to all responsibilities and rights of a company’s management, board and shareholders. It includes topics such as management structure, employee relations, executive and employee compensation.

In view of the broad scope of the definition of sustainability risks as per the SFDR, most investments could be exposed to sustainability risks (to varying degrees).

These risks are always considered an integral and mandatory part of the assessment in our investment process. We identify potential sustainability risks associated with the investment from an ESG-point of view for every EuVECA and every investment pursued. Identified potential or emerging risks are identified, analyzed and submitted to the Investment Committee by the risk management representative.

The Investment Committee deliberates about the sustainability risk(s) with the same importance as any other material risk factor(s) an investment might entail. The investment committee takes its investment decision following the latest available fund investment policies,objectives and overarching regulatory requirements. Sustainability risks would not in itself prevent the Company from making an investment. Instead,sustainability risks form part of the Company’s overall risk management processes and is one of many risks which may, depending on the specific investment opportunity, be relevant to the Company’s determination for risk.

The risks resulting from environmental, social or governance events can have sudden and significant negative consequences on the value of the investments held in the portfolio.

The Company implements exclusion lists in its management policy. These lists are drawn up on the basis of various external sources :

- The first exclusion concerns companies (or entities held, owned or controlled by persons) included on national or supranational exclusion/sanction lists in relation to the fight against money laundering and the financing of terrorism or companies domiciled in countries included on such lists;

- The second exclusion concerns the investments (whatever its form) in companies that operate in a business or sector such as (i) any illegal economic activity, or (ii) the production of and/or trade in weapons and ammunition of any kind; or that contravene any applicable law or regulation, or accepted standards of moral or ethical behavior, or is associated with such activities.

b. Remuneration Policy

The Company’s remuneration policy aims to:

Ensure that remuneration is in line with the business strategy, objectives, values and interests of the Company, its EuVECAs and the investors of the clients’ EuVECAs, where applicable;
Not encourage risk‐taking that is inconsistent with the risk profiles, rules or articles of incorporation or management regulations of the EuVECA Fund or its clients’ EuVECAs;
Ensure consistency with and promotion of sound and effective risk management to avoid excessive risk-taking;
Ensure consistency with the consideration of sustainability risks;
Avoid or manage conflicts of interest.

3. No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors (Art. 4 (1) (B))

Pursuant to article 4 of the SFDR, the Company, taking into account in particular its size, is allowed not to take into account adverse impacts of investment decisions on sustainability factors as defined in the SFDR.