Sustainability Disclosure

Sustainability disclosure regarding the Sustainable Finance Disclosure Regulation (SFDR)
Version: 09-08-2021

(a) Summary
In addition to the sustainability policy , the most important aspects of sustainability disclosure are briefly presented in this overview in accordance with the template of the (draft) RTS (Articles 45 to 57) of Regulation (EU) 2019/2088 of the European Parliament and of the Council on disclosures on sustainability in the financial services sector.

(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. Briefly, for each investment, it is examined whether the company has any significant adverse effects on the environment. It also tests whether the company is acting in line 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
All StartGreen funds have a sustainable investment objective. Below you can find a brief overview of the objectives for each fund and the strategy used to achieve this objective. Additional information can be found on the specific fund pages:

The other StartGreen funds do not have to adhere to the SFDR or have been closed and are therefore not included in the above overview.

(d) Investment strategy
The fund tries to achieve its objective by providing financing to companies that evidently make a contribution to the objective described under c. Good governance at the companies is safeguarded by means of the ESG policy (including management structure, employee relationship, 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. Through these, an estimate is made of the potential impact. Subsequently, the progress on the selected impact KPIs is monitored at least once a year for each company. Finally, the data is aggregated at fund level once a year, so that the contribution to the target can be monitored.

(g) Methodologies
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 guarantee data quality: before closing, the assumptions made during analysis are validated as much as possible by multiple sources during the due diligence (triangulation). In addition, an external investment committee checks the assumptions used. During the management phase, the investment team does sanity checks on the reported figures. In some cases (part of the) data is drawn up 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 checked for major deviations.

How data is processed: data is collected, at least, annually in a reporting format by the investment team. Subsequently, the output of this collection is entered in an impact database after which the data is analysed.

(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 incorrect or lack accuracy.
  • No effect on objectives: large deviations will come to light through sanity checks and benchmarking. Therefore, what remains are mainly minor deviations, with the impact at fund level expected to be limited.
  • Mitigation of constraints: through the accumulation of impact data originating from multiple years and multiple companies, increasingly better comparisons can be made. This improves detection of anomalies, which helps to reduce the effects of 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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