Sustainability related disclosures
In order to comply with the sustainable finance disclosure regulation (SFDR¹), Nedvest Capital
Management B.V. (Nedvest) makes the following disclosures.
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”.
Prior to any investment decision made on behalf of a fund that Nedvest manages, part of the
investment decision-making process involves ESG considerations. Herein, Nedvest assesses the risks
attached to a potential investment opportunity, which includes sustainability risks.
In addition, Nedvest pays its staff a combination of fixed and variable remuneration (including a
possible bonus). The variable remuneration is based on compliance with all policies and procedures at
Nedvest, including those relating to sustainability risks within the investment decision-making process.
Employees are made aware of the applicable policies and procedures when starting their employment
No consideration of sustainability adverse impacts
Sustainability factors are integrated in the investment decisions process of Nedvest. However, we will
not consider adverse impacts of investment decisions on sustainability factors² as set forth in article 4
sub 1 (a) of the SFDR. Given the small size of the organization of Nedvest itself and the impact on
certain of the portfolio companies, such disclosure as set forth article 4 sub 1 (a) of the SFDR and the
administrative burden in connection therewith would not be proportional.
¹Regulation (EU) 2019/2088
²As set out in article 4 sub 1 (b) of the SFDR in conjunction with article 4 sub 1 (a) SFDR