Sustainability information regarding the Sustainable Finance Disclosure Regulation (SFDR)
In line with the template of the (draft) RTS (Articles 45 to 57) supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council on disclosure of sustainability in the financial services sector. Version: 10-03-2021
Not applicable as this description is already less than two pages, so no summary is considered necessary.
(b) No significant damage to the sustainable investment objective
The fund ensures that the companies in which it invests do not cause significant damage to the sustainable investment objectives through the ESG policy, part of the sustainability policy. In short, for each investment, it is examined whether the company has some significant adverse effects on the environment. It is also tested whether the company acts in accordance with the “Ten Principles of the UN Global Compact” and (if it concerns a multinational company) the “OECD Guidelines for Multinational Enterprises”.
(c) Sustainable investment objective of the financial product
The fund aims to contribute to:
- Energiefonds Overijssel: energy transition
- PDENH: energy transition / sustainable mobility / circular economy
- Borski Fund: diversity
(d) Investment strategy
The fund tries to achieve its objective by providing financing to companies that demonstrably contribute to the objective described under c. Good governance at the companies is safeguarded by means of the ESG policy (including management structure, employee relations, remuneration policy and tax compliance).
(e) Proportion of investments
All financing is aimed at achieving the objective described under c. No other type of investments will be made from the fund.
(f) Monitoring of sustainable investment objective
Prior to financing, a minimum of three impact KPIs are selected for the company that relate to the objective of the fund. Here an estimate is made of the potential impact. Subsequently, the progress on the selected impact KPIs is monitored at least once a year per company. Finally, the data is aggregated once a year at fund level, so that the contribution to the objective can be monitored.
See the appendix of the StartGreen Impact Report for a detailed description of the methodology used.
(h) Data Sources and Processing
Data sources: in most cases the impact is linked to the output of the company. For example 1ton CO2equivalent savings per year per product sold. Data about the output is received from the company. The impact factor is examined by the investment team before financing. Data sources used for this are diverse (scientific articles, internet sources, existing benchmarks, entrepreneurs).
Measures to safeguard data quality: for financing, the assumptions are validated by multiple sources as much as possible during the due diligence (triangulation). In addition, an external investment committee checks the assumptions used. During the management phase, the investment team performs sanity checks on the reported figures. In some cases, (part of) the data is prepared and / or checked by an independent accountant. Finally, data is analyzed at a fund level, whereby the impact of comparable technologies can be compared and can be checked for major deviations.
How data is processed: data is collected at least annually in a reporting format by the investment team. The output of this is then entered into an impact database. Analyzes are performed on this.
(i) Limitations of the methodologies and data
- Limitations: The impact data is not always checked at the detail level of each company every year by an external organization, as this can be a costly and time consuming process. This means that the data sent by the company is not verified by an independent party, which means that the data may be less accurate or incorrect.
- No effect on objectives: major deviations will most likely come to light during sanity checks and benchmarking. What remains are therefore mainly small deviations, whereby the impact at fund level is expected to be limited.
- Mitigation of constraints: By collecting more and more impact data from multiple years and multiple companies, increasingly better comparisons can be made to detect anomalies, trying to reduce the effect of the constraints.
(j) Due diligence
In the investment proposal, a section is devoted to the impact analysis of the company, describing how and how much the company can potentially contribute to the objective. This is based on internal and (if relevant) external research. The proposal is always checked by an external investment committee.
(k) Engagement Policy
The management of the company is often involved with the objectives of the fund from the first contact phase. It provides input for the impact analysis and reports frequently (at least once a year) on the impact made by the company. Progress (and any deviations) with regard to the impact made can be discussed at general meetings of shareholders.
(l) Achieving the sustainable investment objective
For the time being, no external reference benchmark is used.
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