ESG Disclosure

 

Mandatory disclosures under 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”)

 

Information about policies on the integration of sustainability risk in investment decision-making processes (Article 3) 

Commercialization Reactor Fund AIFP, SIA (hereafter “CRF”) considers environmental, social, and corporate governance (hereafter “ESG”) risks in our investment decision-making process. Potential sustainability risks, if they occur, could cause material negative impact on the value of the investment. The scope of ESG risks’ assessment varies depending on the individual investment case. CRF believes that sustainability factors can have both a direct and indirect impact on the return and cost structure of the fund and investments. In order to develop a strong culture that supports ESG practices at both CRF and our portfolio businesses, CRF aims to integrate sustainability considerations into our internal policies in a more thorough manner. As CRF invests in deep-tech innovative start-ups, these technologies often solve widely known circular economy, environmental and social challenges. In most cases these investments in particular have demonstrated more accelerated value growth.

 

CRF applies exclusion policy and does not invest into companies which operate in those sectors of the economy associated with significant sustainability risks, such as trade of alcoholic beverages, gambling and betting, sale of firearms and ammunition, adult entertainment, manufacturing, processing and marketing of tobacco and tobacco products and others. These exclusions are mainly envisaged by public funding regulations under which CRF currently carries out its operation.

 

CRF currently does not offer and does not manage any funds which promote, among other characteristics, environmental or social characteristics, or a combination of those characteristics or funds which have sustainable investment as its objective, thus ESG considerations are regarded as inputs in the investment process rather than the overarching objective of our investment strategy. 

 

CRF implements a state aid program which provides a regulated framework of decision-making process. CRF has been granted the right to implement this program by public procurement that provides narrow room for any adjustments while the contract is executed.

 

Statement of no consideration of adverse impacts of investment decisions on sustainability factors (Article 4) 

CRF currently does not take into consideration the adverse impacts (“PAI”) of investment decisions as defined by Article 4 of the SFDR on sustainability factors as defined by Article 2 (24), due to the size, nature, and scale of CRF activities as well as the types of financial products CRF offers. Investment focus of the funds under our management is pre-seed to seed stage newly created deep-tech start-ups, which, considering their scale of activities, are currently not required to collect and report the data necessary to reliably assess and monitor PAI. Requirements to collect and report such data would, in most cases, be disproportionate to the size of the operations of these companies and resources available to them. CRF will continue to monitor the situation and will re-evaluate our approach whenever more data becomes available or new investment strategies are implemented.

 

Information on consistency of remuneration policies with the integration of sustainability risks (Article 5) 

The structure of remuneration policies does not encourage excessive risk‐taking with respect to sustainability risks.