Kickfund AG disclosures on the basis of the EU Sustainability Finance Disclosure Regulation (EU) 2019/2088 (‘SFDR’)

 

Article 3 of the SFDR requires: “Financial market participants shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process.”

Kickfund AG is a single strategy investment manager that adopts an overall investment decision making and approval process for the fund it manages. During the investment process Kickfund AG will be exposed to potential sustainability risks. Sustainability risks would not in itself prevent Kickfund AG from making an investment. Instead, sustainability risks may form part of Kickfund AG’s overall risk assessment processes, but will typically not be addressed by Kickfund AG as it will invest in a very limited and pre-defined investment universe, i.e. venture kick winners which typically do not address potential 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.”

 

Article 4 of the SFDR requires financial market participants to provide transparency of adverse sustainability impacts at portfolio entity level.

Kickfund AG, for a number of reasons, does currently not consider the principal adverse sustainability impacts of investment decisions on sustainability factors as defined under and in accordance with SFDR. This because of its limited organizational size and that it is currently not in a position to obtain and/or measure all the data which it would be required by SFDR to report on, or to do so systematically, consistently and at a reasonable cost with respect to its investment strategies to its investors. This is in part a result of the fact that investments at portfolio entity level are not generally required to report by reference to the same data.

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Article 5 SFDR requires financial market participants to provide transparency of remuneration policies in relation to the integration of sustainability risks.

Kickfund AG is registered as a ‘light’ manager in terms of the Swiss Financial Institutions Act and would fall outside of the scope of the EU Alternative Investment Fund Managers Directive (‘AIFMD’) and is as a consequence not required to prepare a remuneration policy as described in the AIFMD. Kickfund AG pays staff members a remuneration notwithstanding any integration of sustainability risks.