General

At Finquiddity Vermogensbeheer B.V. (Polestar Capital) making impact is as important as making financial returns for our investors. To secure the needed resources and focus for our impact and sustainability ambitions, we have designated impact to be a central theme in our corporate and fund policies. Polestar Capital has developed a sustainability policy describing its vision and strategy on sustainability and the manner in which such vision and strategy are integrated into our investment processes and procedures. Additionally, the risk management policy describes amongst others how Polestar Capital identifies sustainability risks, determines the possible mitigation measures to be taken, and the way to monitor these risks and measures. Both policies are approved and monitored by the Polestar Capital’s Executive Board.

Polestar Capital acts as a manager of alternative investment funds (the Funds) within the meaning of the Alternative Investment Fund Managers Directive (EU 2011/61, as amended or restated from time to time, AIFMD). Polestar Capital has obtained a license pursuant to article 2:65 of the Dutch Financial Supervision Act (Wet op het financieel toezicht, Wft)1 from the Dutch Authority for the Financial Markets (Stichting Autoriteit Financiële Markten, AFM) in respect of the management and offering of the Funds. Polestar Capital is subject to European sustainability regulations that are issued pursuant to the EU Action Plan ‘Financing Sustainable Growth’, including amongst others, the Sustainable Finance Disclosure Regulation (SFDR) and the Taxonomy Regulation (TR).

This website statement describes Polestar Capital’s approach with regards to and application of the several requirements contained in the SFDR.

Integration of Sustainability Risks in the investment decision-making process

‘Sustainability Risks’ within the meaning of the SFDR are defined as ‘an environmental, social or governance event or condition that, if it were to occur, would cause a real or potential material adverse effect on the value of the investment’.

Polestar Capital integrates Sustainability Risks (whether material or likely to material) in its investment decision-making process in respect of the Funds. Before making an investment in or providing financing to projects and portfolio companies, our investment team performs an investment due diligence and checks whether and, if so, which Sustainability Risks an investment in the relevant project or company at hand is or may likely be exposed to. During the investment selection phase, Polestar Capital applies the procedures included in its sustainability policy. As part of such procedures, Polestar Capital checks if projects or portfolio companies would, for example:

• be located a climate sensitive areas and consequently, could potentially be more exposed to extreme heat or flooding;
• have measures in place to create a safe working environment; and
• be active in sectors generating a higher risk of issues in regards to governance and fraud.

Furthermore, Polestar Capital assesses whether there are any material reasons (such as unacceptable or unmanageable Sustainability Risks) which would prevent Polestar Capital from investing in such project or company.

By means of the application of its sustainability policy and its risk management policy, Polestar Capital intends to also secure the mitigation and, to the extent this is not possible, the management and monitoring of the identified Sustainability Risks its investments may be exposed to. The identified Sustainability Risks, the measure(s) taken and the details of the monitoring of the Sustainability Risks are recorded in the internal systems of Polestar Capital. Polestar Capital would update its sustainability policy and risk management policy to address the outcome of such monitoring if and to the extent required.

No consideration of adverse impacts of investment decisions on sustainability factors

‘Sustainability Factors’ within the meaning of the SFDR are defined as ‘environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.’

Investment decisions of Polestar Capital could have adverse impact on Sustainability Factors. Currently, Polestar Capital does not consider any principal adverse impacts (PAIs) of its investment decisions on Sustainability Factors on an entity level.

Polestar Capital is unable to fulfil the detailed requirements regarding the PAIs pursuant to the SFDR Delegated Regulation (EU 2022/1288) due to the lack of available data or the fact that a large part of the projects or companies in which Polestar Capital invests choose to not publicly disclose the data required for such reporting and such data cannot be obtained otherwise.

Regardless of the above, Polestar Capital maintains the ambition to report on PAI’s conform the SFDR Delegated Regulation in the future. Polestar Capital will therefore closely observe market practices and future regulatory changes, and will periodically engage with its investees to discuss the availability of (part of) the required data, in order to evaluate the feasibility of Polestar Capital considering any PAIs of its investment decisions on Sustainability Factors as of such date.

Polestar Capital Remuneration policy relating to the integration of sustainability risks

As sustainable investing is at the core of Polestar Capital, sustainability risks are taken seriously. Polestar Capital has a controlled remuneration policy which supports sound and effective risk management, ensuring not to expose Polestar Capital and the Funds to excessive risks. Through its remuneration structure and by means of the application of its remuneration policy, no excessive risks are incentivised, which clearly also includes Sustainability Risks.

More specifically in connection with the performance review of Polestar Capital's staff, it is assessed whether and to what extent a staff member has taken sufficient efforts to duly and effectively execute the investment processes and risk management policies of Polestar Capital, which includes the identification, mitigation and management of Sustainability Risks. By doing so, Polestar Capital ensures the consistency of the remuneration policy with the integration of sustainability risks.

1 - As part of the license granted by the AFM, Polestar Capital has been given the authorisation to also perform activities pursuant to article 2:67a, subsection 2, under a, b and d of the Dutch Financial Supervision Act.

Initial version: 1-1-2024

Latest update: 23-10-2024