Below are Private Equity Advisors AIFM A/S’s (“ATP PEP”) required website disclosures, cf. the EU Sustainable Finance Disclosure Regulation (2019/2088) (the “Disclosure Regulation”).
The Disclosure Regulation sets out several requirements for financial market participants regarding disclosures to the public relating to information on the integration of sustainability risks and principal adverse impacts.
Required website disclosure pursuant to Article 3 of the Disclosure Regulation
Sustainability risks means an environmental, social or governance events or incidents that if they occur could cause an actual material negative impact on the value of the investment.
ATP PEP has well integrated processes for considering ESG factors and assess relevant sustainability risks through due diligence prior to investment recommendations and investment decisions being made. ATP PEPs Head of ESG lead the work of integrating ESG into investment processes.
Sustainability risks are present in almost all types of investments and as a fund-of-funds manager sustainability risks cannot be avoided. As investments normally are blind-pool investments, it is not possible to make a concrete assessment of the portfolio companies, as they are not known at the time of investment. Thus, ATP PEP integrates – i.e. considers – relevant sustainability risks on an overall level in its due diligence of potential commitments to funds managed by ATP PEP.
Required website disclosure pursuant to Article 4 of the Disclosure Regulation
According to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (the “Disclosure Regulation”), financial market participants – such as ATP PEP – are required to disclose whether such financial market participants include considerations of “principal adverse impacts” on “sustainability factors” in their investment decisions or not.
The Disclosure Regulation stipulates that if a financial market participant does not include considerations of “principal adverse impacts” on “sustainability factors” in investment decisions, the financial market participant must on its website disclose clear reasons for why it does not do so.
At present, ATP PEP does not – within the meaning of Article 4(1)(a) of the Disclosure Regulation – consider the “principal adverse impact of its investment decisions on sustainability factors” for any of the financial products it offers. ATP PEP does not currently do so, as our investment strategy, includes investment in small and midcap private equity funds (many of which are located outside the EU /EEA as are many of the investments by such private equity funds), renders it difficult to collect sufficient data to always correctly identify and report on potential principal adverse impact on the specific “sustainability factors”.
ATP PEP will, however, on a regular basis evaluate whether to potentially consider “principal adverse impacts” on “sustainability factors” (as this is defined in the Disclosure Regulation) in future investments, (including as more methodology guidelines become available from Danish or EU regulators in respect of the Disclosure Regulation.)
Required website disclosure pursuant to Article 5 of the Disclosure Regulation
ATP PEP does not have a variable remuneration program and therefore sustainability risks have not specifically been considered in remuneration policies.
Required website disclosure pursuant to Article 8 of the Disclosure Regulation
This Fund promotes environmental or social characteristics but does not have as its objective a sustainable investment focus. Please refer to the pre-contractual disclosures regarding the funds managed by ATP PEP in the links below:
Required website disclosure pursuant to Article 10 of the Disclosure Regulation – sustainability related disclosures