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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. Strategies for dealing with sustainability risks in investment decision-making processes (Article 3 of the Disclosure Regulation)
The EMERAM Private Equity Fund I GmbH & Co. KG ("EMERAM I KG") is a long-term investor with a focus on the technology/software, value-added services and new consumer staples sectors. Investment decisions also take into account environmental, social and governance (ESG) criteria to the extent that they are relevant to the respective sector of the portfolio company. When EMERAM I KG reviews investment opportunities, ESG due diligence is carried out as required to assess potential sustainability risks. Sustainability risk within the meaning of the Disclosure Regulation means an environmental, social or governance event or condition, the occurrence of which could have an actual or potential material adverse effect on the value of the investment.
II. Mandatory disclosures on the consideration of adverse sustainability impacts at the level of EMERAM Private Equity Fund I GmbH & Co. KG (Article 4 of the Disclosure Regulation)
Art. 4 of the Disclosure Regulation provides a framework for creating transparency with regard to any adverse effects of investment decisions on sustainability factors within the meaning of the Disclosure Regulation. To this end, financial market participants such as EMERAM Private Equity Fund I GmbH & Co. KG ("EMERAM I KG") have to disclose certain information (presumably from July 2022 onwards, taking into account so-called Regulatory Technical Standards (RTS)). The EMERAM I KG is of the opinion that the information provided to it by the portfolio companies with regard to the investments (in particular with regard to the comprehensive requirements of the RTS) is not yet sufficient to enable this. At present, it can therefore be assumed that the EMERAM I KG does not yet take into account any adverse effects of investment decisions on sustainability factors within the meaning of Art. 4 of the Disclosure Regulation. However, the EMERAM I KG will monitor the development in the area of available information and examine to what extent it will be reasonably possible in the future to disclose the information required by Art. 4 of the Disclosure Regulation (including the future RTS).
III. Mandatory disclosures on remuneration policy in connection with the consideration of sustainability risks (Article 5 of the Disclosure Regulation)
According to Art. 5 of the Disclosure Regulation, financial market participants must include information in their remuneration policy on the extent to which it is consistent with the inclusion of sustainability risks.
The EMERAM Private Equity Fund I GmbH & Co. KG, as a registered capital management company within the meaning of Section 2 (4) KAGB, does not have remuneration guidelines (remuneration policy) in accordance with the requirements of the KAGB.