Sustainability information regarding the Sustainable Finance Disclosure Regulation (SFDR)
StartGreen Capital integrates sustainability risks into its investment and financing decisions in accordance with Article 3 of the Sustainable Finance Disclosure Regulation (SFDR). We define a sustainability risk as an environmental, social, or governance event or condition that, if it occurs, could have a material negative effect on the value, continuity, or risk profile of an investment.
We believe that companies and projects that identify and manage sustainability risks in a timely manner are better positioned to create long-term value. Therefore, we not only assess the potential financial impact of ESG risks, but also look at the opportunities arising from sustainable innovation, more efficient use of resources, strong governance, and future-proof business models.
While our impact policy focuses on achieving positive social and environmental impact, our ESG policy focuses on identifying, assessing, and managing potential negative effects and sustainability risks. In this way, both policy frameworks reinforce each other and contribute to a robust and future-proof portfolio.
Sustainability risks are taken into account throughout the entire investment cycle through an integrated approach:
- ESG screening and selection: Before a company or project qualifies for financing, we assess whether it fits within the objectives, criteria, and principles of the relevant fund. In doing so, relevant ESG risks, exclusion criteria, and points of attention are identified.
- ESG due diligence: During the investment analysis, we assess relevant sustainability risks and ESG factors, including climate and transition risks, biodiversity, human rights, working conditions, governance, and risks within the value chain. It is also assessed to what extent these factors could lead to operational, legal, regulatory, or reputational risks that could have a material effect on the investment.
- Monitoring and engagement: After investment, material sustainability risks and ESG factors are actively monitored throughout the term of the investment. This is done, among other things, through periodic reporting, ESG inquiries, and engagement with portfolio companies and project organizations aimed at identifying, mitigating, and managing risks and promoting improvements.
By structurally integrating sustainability risks into our investment process, we strive for a portfolio that is not only financially attractive but also resilient, responsible, and future-proof. We are convinced that companies that effectively manage ESG risks and respond to sustainability opportunities are better able to attract talent, retain customers, attract capital, and create long-term value. In doing so, they contribute not only to a positive social impact but also to a stable and sustainable return for our investors.
Below you will find an overview of the ESG themes and assessment criteria that we analyze prior to an investment or financing decision.
No consideration of adverse impacts on sustainability at entity level (Article 4 SFDR)
StartGreen Capital currently does not take into account the principal adverse impacts of its investment decisions on sustainability factors (Principal Adverse Impacts or PAIs) at entity level, as referred to in Article 4(1)(a) of the SFDR. StartGreen Capital therefore makes use of the disclosure option (explain option) as referred to in Article 4(1)(b) SFDR and does not publish a PAI statement at entity level.
A significant proportion of the companies and projects in which the funds managed by StartGreen Capital invest concern smaller companies or companies in an early stage of development. Due to their size, not all portfolio companies are required to report (audited) ESG data. As a result, sufficient reliable, consistent, and verifiable information is not available for all relevant PAI indicators. In addition, such data is often not publicly accessible and only limitedly available through external data providers. StartGreen Capital can therefore currently not guarantee that the data required for full reporting in accordance with Article 4 SFDR is sufficiently complete, consistent, and of the required quality.
StartGreen Capital will assess annually whether developments in the availability, quality, and reliability of ESG data provide reason to consider PAIs at entity level after all.
Although StartGreen Capital currently does not consider PAIs at entity level within the meaning of Article 4 SFDR, potential negative sustainability impacts are included in the investment process. This is done, among other things, through ESG screening, ESG due diligence, monitoring of portfolio companies, and active dialogue with companies and projects in which investments are made.
In addition, funds managed by StartGreen Capital may, depending on their SFDR classification, fund documentation, and investment strategy, take PAI indicators into account at product level in accordance with Article 7 SFDR. In that case, this is reported in the relevant fund documentation and periodic reports.
Remuneration policy regarding the integration of sustainability risks (Article 5 SFDR)
StartGreen Capital maintains a remuneration policy that is in accordance with Article 5 of the SFDR. The remuneration policy is aimed at aligning the long-term interests of the company, its employees, investors, and other stakeholders and contains no incentives to take excessive risks, including sustainability risks.
The remuneration policy supports controlled and ethical business operations and promotes a careful consideration of financial, operational, and sustainability-related risks when making investment and financing decisions. Variable remuneration, where applicable, is moderate in size, discretionary in nature, and dependent on both individual performance and the financial position and continuity of StartGreen Capital. It is not exclusively linked to commercial or financial objectives.
As an impact-driven fund manager, StartGreen Capital has the statutory objective to make a significant positive contribution to people, the environment, and society through its business operations and activities. The remuneration policy is therefore designed in such a way that employees are not encouraged to take irresponsible sustainability risks or ignore negative effects on sustainability factors in order to achieve financial objectives.
Relevant ESG risks and sustainability factors are taken into account in investment and financing decisions in accordance with StartGreen Capital’s ESG policy and internal decision-making processes. Results achieved by taking irresponsible sustainability risks do not form a basis for awarding variable remuneration.
Through this link between remuneration, risk management, and ESG integration, the remuneration policy contributes to long-term sustainable value creation and supports the objectives, mission, and legal obligations of StartGreen Capital.
Website fund disclosures (Article 10 SFDR)
In addition to the sustainability policy, the main aspects of sustainability information per fund are briefly presented below. 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.
StartGreen Climate Impact Equity Fund
Energiefonds Overijssel
- SFDR Article 10 – Website disclosure
- SFDR RTS Annex V – Periodic disclosure
- No pre-contractual SFDR‑information available; fund established before SFDR came into effect.
ASN Energie & Innovatiefonds
- SFDR pre-contractual information
SFDR Article 10 – Website 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 above overview.
