ESG (Environmental, Social and Governance) is a term that refers to three key factors that are taken into account when evaluating the sustainable and responsible performance of companies and investments – environmental, social and governance. ESG refers to an investment approach that, in addition to financial indicators, also takes into account non-financial criteria when making investment decisions.
ESG consists of three pillars:
Environmental – refers to the environmental impact of companies’ activities and includes issues related to greenhouse gas emissions, energy consumption, energy efficiency, waste management, natural resource conservation, climate change, air and water pollution, and biodiversity protection.
Social – refers to the impact of business activities on society, employees, customers, suppliers and local communities. Social issues include human rights, working conditions and compensation, diversity and equality policies, employee health and safety, stakeholder relations and corporate social responsibility.
Governance – refers to the governance and control processes of companies and includes aspects such as transparency, business ethics, corporate responsibility, independence of supervisory bodies, composition and compensation of management bodies, and risk management approaches.Implementing an ESG approach involves integrating these three factors into the organization’s strategy and practices, and then monitoring and evaluating the company’s actions with appropriate indicators. This allows investors to better understand the risks and potential associated with a given investment.
European authorities prioritize sustainability issues, so they have developed a legal framework for considering ESG factors in the financial sector. These regulations require financial market participants to disclose detailed information on sustainability risks.
The key ESG legislation that has been adopted by the EU employer for the financial sector is:
– Regulation (EU) 2019/2088 of November 27, 2019 on the disclosure of information related to sustainability in the financial services sector (the “SFDR Regulation“).This regulation introduces an obligation for financial market participants and financial advisors to disclose information related to sustainability objectives, as well as distinguishes between financial products that are related to sustainability and those that are not. – Commission Delegated Regulation (EU) 2022/1288 of April 6, 2022. supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards setting out details on the content and presentation of information in relation to the “do no serious harm” principle, specifying the content, methods and presentation of information in relation to sustainability indicators and adverse sustainability effects, and specifying the content and presentation of information in relation to the promotion of environmental or social aspects and sustainable investment objectives in pre-contractual documents, websites and periodic reports (the “RTS Regulation“).
– Regulation (EU) 2020/852 of June 18, 2020 on establishing a framework to facilitate sustainable investments, amending Regulation (EU) 2019/2088 (“Taxonomy“).
In performance of the obligations set forth in the referenced legal acts, Valuetech Seed. Sp. z o.o., based in Wroclaw, Poland (hereinafter: “the Company“), acting as manager of alternative investment companies, declares as follows.
Strategy for incorporating risks for sustainable development into operations.
In fulfillment of the obligation referred to in Article 3 (1) of the SFDR Ordinance, the Company declares that, at this stage, it does not have a strategy for incorporating sustainability risks into its operations in its investment decision-making process.
Pursuant to Article 2(22) of the SFDR Regulation, risks to sustainability means environmental, social or governance situations or conditions that, if they occur, could have, actual or potential, a material adverse effect on the value of an investment.
The Company considers that, at present, risks to sustainability do not materially affect the return on the financial products it offers (alternative investment company). This assessment was made after taking into account factors such as the type of financial product offered by the Company, the planned size of the Company’s operations in the near term, the permissible types of deposits adopted in ASI’s investment policy and strategy, the criteria for selecting deposits, the rules for diversifying deposits, and the diversified catalog of sectors in which ASI will seek potential deposits.
The Company will monitor risks to sustainability on an ongoing basis, and in the event that an increase in their impact on the return on participation in ASI is identified, the Company will take appropriate action to provide relevant information to ASI investors.
When making investment decisions, adverse effects on sustainability factors are not taken into account.
In fulfillment of the obligation referred to in Article 4(1)(b) of the SFDR Regulation and Article 12 of the RTS Regulation, the Company announces that it does not take into account the main adverse effects of investment decisions on sustainability factors.
The Company justifies its decision by the early stage of ASI’s activities, the scale of these activities and assumptions about the course of the investment process, as well as the type of financial products made available and the limited availability and quality of data necessary to conduct an analysis on ESG factors.
The Company will consider taking into account the adverse effects of investment decisions on sustainable factors in the event of an expansion in the scale of its operations and the increased availability of sustainability reporting data in the future.