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Mandatory disclosures under the Regulation of the European Parliament and of the Council on sustainability-related disclosure requirements in the financial services sector (EU) 2019/2088 (“SFDR”):
I. Transparency of sustainability risk policies (Article 3 SFDR)
EMERAM Private Equity Fund I GmbH & Co. KG, EMERAM B&M Continuation Fund GmbH & Co. KG and WinIT Continuation GmbH & Co. KG are internally managed special AIFs (collectively the “Funds”) and long-term investors that embrace their responsibility towards investors, portfolio companies and stakeholders in the wider ecosystem in which the Funds and their portfolio companies operate. The Funds consider sustainability related risks in their investment decision as well as in the management of their investment portfolio. Furthermore, sustainability risks may be considered as part of the due diligence and risk assessment processes in advance of each investment.
II. No consideration of adverse impacts of investment decisions on sustainability factors (Article 4 SFDR)
Article 4 SFDR provides for a framework aimed at achieving transparency with regard to any principle adverse impacts of investment decisions on sustainability factors. For this purpose, financial market participants such as the Funds must disclose certain information (taking into account the Commission Delegated Regulation (EU) 2022/1288 (“RTS”) with regard to regulatory technical standards). Currently, the Funds do not take into account any principle adverse impact of investment decisions on sustainability factors as provided for by the RTS, as they believe that the information provided to it by the portfolio companies in relation to the investments is not sufficient to allow it to do so. The Funds will monitor developments with regard to available information and consider whether it is reasonably possible in the future to disclose the information required by the Article 4 SFDR-framework (including the RTS).
III. Transparency of remuneration policies in relation to the integration of sustainability risks (Article 5 SFDR)
As registered internally managed AIFs within the meaning of section 2(4) of the German Capital Investment Code (Kapitalanlagesetzbuch) in conjunction with section 17(2) no. 2 of the German Capital Investment Code (Kapitalanlagesetzbuch), the Funds do not have a remuneration guideline (remuneration policy) in accordance with the requirements of the German Capital Investment Code (Kapitalanlagesetzbuch). Accordingly, the integration of sustainability risks is not considered with respect to the determination of the remuneration.