Creandum Select Fund Manager AB (the “Fund Manager”) makes the following disclosure in accordance with 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 (“SFDR”) and the Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (“Taxonomy”).
The SFDR, Article 2(22), defines sustainability risk as “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment”, below “ESG factors”. The SFDR does not define more specifically what is meant by “material” in this context. The assessment and management of sustainability-related risks are an integral part of the investment process.
As part of the due diligence of a potential investment, sustainability risks are considered and evaluated through an ESG rating, which forms part of any investment recommendation. If deemed relevant, appropriate steps may be taken to avoid or mitigate the sustainability risk.
In the Fund Manager’s view, sustainability risks, particularly where unmitigated, could affect the value of investments held by a fund and/or the ability of the fund to dispose of investments, and hence the value of the fund. However, given the type of investments targeted by the funds, the Fund Manager currently assesses and finds that the sustainability risks impact the returns of the funds only to a minor extent.
Currently, the Fund Manager has decided not to consider any adverse impacts of investment decisions on sustainability factors as set out in the SFDR. Adverse impacts on sustainability factors refer to the investment’s negative impacts on environmental, social, and employee matters, respect for human rights, anti-corruption, and anti-bribery matters. Therefore, the Fund Manager does not report on the sustainability indicators listed in Annex I of the Regulatory Technical Standards (Delegated Regulation (EU) 2022/1288, “RTS”) to identify and assess potential adverse impacts. The Fund Manager has instead decided to focus on specific sustainability risk indicators in the investment decision process fit for the fund’s investment strategy, rather than to consider the indicators set out in Table 1-3 of Annex 1. The Fund Manager therefore considers the existing sustainability due diligence processes are appropriate, proportional, and tailored to the investment strategy of the funds it currently manages.
The Fund Manager will, however, continuously assess whether the existing sustainability due diligence processes and procedures are appropriate, proportional, and tailored and will, where required, or otherwise advisable, evaluate whether to consider principal adverse impacts.
The Fund Manager has a total remuneration model consistent with the integration of sustainability risks in the investment process and consisting of both fixed and variable remuneration. Where variable remuneration is paid, it is based on the fulfillment of criteria/targets, both financial and non-financial, as well as an individual's compliance with policies and procedures, including sustainability-related policies
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