Sustainability disclosures (SFDR)

SFDR Statement

This page contains the disclosures of the Fund Manager under the EU Sustainable Finance Disclosure Regulation (SFDR) in respect of Plethora Private Equity (the Master fund) and Plethora Accelerator Coöperatief U.A. (the Feeder fund). Both funds have been classified as Article 6 funds under the SFDR; the disclosures below apply to both funds.

The investments of the Funds do not take into account the EU criteria for environmentally sustainable economic activities. However, in compliance with the SFDR, the Fund Manager does consider the effects of material sustainability risks on the value of the Funds’ investments. On a company by company basis, all relevant ESG/sustainability risks are defined and assessed during the initial due diligence and on an ongoing basis after an investment is made. In accordance with the SFDR and the Taxonomy Regulation, the Fund Manager is required to provide information regarding sustainability concerning the Funds; this page provides that information.

Qualification of the Funds

The Funds qualify under Article 6 of SFDR. They do not promote environmental or social characteristics (‘light green investments’ as referred to in Article 8 of SFDR) and also do not have sustainable investment as their objective (‘dark green investments’ as referred to in Article 9 of SFDR). The underlying investments of these financial products do not take into account the EU criteria for environmentally sustainable economic activities.

Policy on sustainability risks

The Fund Manager acknowledges that the realization of sustainability risks can potentially have a negative impact on the value of investments. A sustainability risk, in essence, refers to an event in the environmental, social, or governance (ESG) domain that could adversely affect the value of the Units. Sustainability risks in the environmental domain, for instance, encompass issues like CO2 emissions, energy consumption, and biodiversity loss. On the social front, sustainability risks might pertain to product liabilities and the respect of human rights. In the case of governance-related sustainability risks, considerations could involve inclusivity, diversity, compensation, and corporate ethics. The Fund Manager integrates sustainability risks to a limited extent in investment decisions. On a company by company basis, all relevant ESG/sustainability risks are defined and assessed during the initial due diligence and on an ongoing basis after an investment is made.

No consideration of adverse impacts of investment decisions on sustainability factors

The Fund Manager does not consider the adverse impacts of investment decisions on sustainability factors and therefore does not annually prepare a so-called Principal Adverse Sustainability Impact statement (PAI). Taking into account the adverse impacts of investment decisions on sustainability factors would require the Fund Manager to report on this matter. The necessary information for reporting is currently not available within the Fund Manager. Obtaining such information would necessitate the Fund Manager to undertake (costly) measures. The Fund Manager considers this to be disproportionate, especially since investors are not expected to attach significance to a PAI. The foregoing does not preclude the Fund Manager from reconsidering the decision not to account for adverse impacts of investment decisions on sustainability factors, should relevant circumstances arise. For instance, if the majority of investors request a PAI.

Sustainability risks and remuneration policy

Under the AIFMD registration regime, the Fund Manager is not obligated to adhere to the legally prescribed remuneration policy. Given the limited size of the organization, it was decided not to (voluntarily) establish a specific remuneration policy. Due to the absence of (an obligation to establish) a remuneration policy, the SFDR requirement regarding the provision of information about the remuneration policy and the extent to which that policy aligns with sustainability risks does not apply to the Fund Manager.