In order to comply with the Sustainable Finance Disclosure Regulation (“SFDR”) 1 , Slingshot
Management B.V. (“Slingshot Ventures”) (registered by the Dutch Authority for the Financial Markets (AFM) as an AIFM), on behalf of the funds it manages (registered by the AFM as AIFs), including but not limited to Slingshot Ventures II Coöperatief U.A. and Slingshot Ventures 3 Coöperatief U.A., makes the following disclosures.
A sustainability risk means "an environmental, social or governance (ESG) 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 an AIF managed by Slingshot Ventures, an investment decision process is followed which requires the approval of its statutory directors and in certain cases the Advisory Board of a specific AIF. The ESG impact of potential investments is a standard topic in the investment and due diligence process. Part of the investment decision making process is that Slingshot Ventures assesses and considers the risks attached to a potential investment opportunity, which includes sustainability risks.
In addition, Slingshot Ventures pays its staff a fixed remuneration, with the potential to provide
discretionary bonuses. Discretionary bonuses for relevant staff also takes into account compliance with all policies and procedures which are in effect within Slingshot Ventures, 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 Slingshot Ventures.
In accordance with article 4 sub 1 (b) of the SFDR, Slingshot Ventures 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. Given the small size of the organisation of Slingshot Ventures, 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.