Skip to main content

Sustainability Disclosure

Sustainability disclosure regarding the Sustainable Finance Disclosure Regulation (SFDR)

Sustainability risks (Article 3 of the SFDR)

StartGreen Capital's ESG policy describes how sustainability risks are identified and mitigated by the funds. 'Sustainability risk' is defined as an environmental, social or governance event or circumstance that, if it occurs, could have a material adverse effect on the value of the investment.

The aim of our ESG policy is to identify both ESG risks (potential negative return effects) and ESG opportunities (potential value enhancement). In this way, we exclude sectors that do not align with our values, such as the arms industry, oil and gas industry (fossil fuels), tar sands oil companies and the tobacco industry. During the due diligence phase, we identify potential company-specific ESG risks, such as nitrogen emissions, and opportunities, such as strengthening diversity. If we decide to invest, material ESG risks (if present) are periodically monitored. The combination of these practices should lead to lower risks (such as reputational risk), more future-proof and attractive portfolio companies (for both talent and future investors) and therefore to better returns. Below you can see the ESG process in a schematic overview.

Before we provide financing to a company, we investigate with our ESG survey whether the company has a potentially negative impact on sustainability factors ('inside-out'), such as environmental pollution or child labor in the supply chain. We also analyze per company whether it faces serious external sustainability risks ('outside-in'), for example a physical climate risk that, if it materializes, could lead to a material adverse effect on the value of the investment.

Below you will find an overview of the ESG items that we analyze prior to providing financing.

Consideration of the Principal Adverse Impacts (Article 4 of the SFDR)

Since 2021, StartGreen Capital has been conducting an annual survey among its portfolio companies to report on topics arising from the SFDR, including the 'adverse effects on sustainability', better known by the English name “Principal Adverse Impacts” (PAIs). These concern indicators of potentially adverse effects on people (including diversity, employee safety, human rights) and the environment (including greenhouse gases and waste or biodiversity).

Many of StartGreen Capital’s portfolio companies are relatively young and small. Due to the size of the companies, data on these is often not publicly available or available via a data provider (as is the case with some large listed companies). In addition, the portfolio companies themselves often do not have the resources and/or obligation to report on these PAI indicators. The survey is therefore completed on a “best-effort” basis. Because StartGreen Capital is dependent on the quality of the information it receives from portfolio companies, it was unable in previous years to guarantee the necessary completeness and quality required for a publication of PAI statements.

From financial year 2024 onwards, StartGreen Capital will report on Principal Adverse Impacts (PAIs) in accordance with article 4 of the SFDR at entity level. StartGreen Capital's aim is to improve the quality and completeness of this information every year, by, among other things, providing better guidance to portfolio companies and using improved applications.

Since StartGreen Capital invests in sustainable companies based on its mission and many of the PAI indicators have already been assessed during the ESG due diligence, the likelihood of material, negative effects is considered small.


Remuneration policy with regard to the integration of sustainability risks
(Article 5 of the SFDR)

StartGreen Capital pays all employees a fixed monthly compensation that is not dependent on targets. StartGreen Capital can pay discretionary variable rewards, these are rewards that are linked to achieving criteria in relation to the employee's performance, but also in relation to the financial solidity of StartGreen Capital. The ratio between fixed and variable rewards is appropriate and can never exceed 20 percent of the fixed income. StartGreen Capital does not work with guaranteed variable rewards.

StartGreen Capital has the statutory objective to 'have a significant positive impact on society and the environment in general through its business operations and activities'. Employee remuneration is therefore always linked to objectives that ideally make a positive contribution to, but in no case have a negative impact on, one of the Sustainable Development Goals. Investments and financing may only be eligible for the quantitative objectives if the ESG risks have been sufficiently assessed and approved in advance by the committee mandated for this purpose.

Read it here full remuneration policy.


Website fund disclosures (Article 10 of the SFDR)

In addition to the sustainability policy Below, the most important aspects of sustainability information are briefly presented per fund. These overviews are in accordance with Articles 45 to 57 of the Delegated Regulation (EU) 2022/1288 (SFDR RTS). In addition, the “periodic disclosures” from the annual reports of the funds – as described in Annex V of the SFDR RTS – are linked.

Energiefonds Overijssel
– SFDR article 10 – Web site disclosure

Participation Fund Sustainable Economy North Holland
– SFDR article 10 – Web site disclosure
– SFDR RTS Annex V – Periodic disclosure

Borski Fund
– SFDR article 10 – Web site disclosure
– SFDR RTS Annex V – Periodic disclosure

The other mandates of StartGreen Capital do not fall under the SFDR or have since been closed and are therefore not included in the overview above.

StartGreen Capital
Mauritskade 64
1092 AD Amsterdam
View on Google Maps

Phone:
+31 (0)20 568 20 60
E-mail:
info@startgreen.nl

en_GBEnglish (UK)