Sustainability-Related Disclosures
This disclosure ensures compliance with the Sustainable Finance Disclosure Regulation (SFDR 2019/2088 and 2022/1288).
As these regulations have not yet been fully consolidated, the first part of this disclosure addresses SFDR 2019/2088 and the second part SFDR 2022/1288.
SFDR Statement (2019/2088)
The following disclosure relates to Robin Capital GmbH (LEI: 391200T8Z95JVC8G1M46):
This statement includes three sections:
Transparency of sustainability risk policies (2019/2088 – 3-1)
Transparency of adverse sustainability impacts (2019/2088 – 4-1-b)
Transparency of remuneration policies in relation to the integration of sustainability risks (2019/2088 – 5)
Transparency of Sustainability Risk Policies
Robin Capital GmbH addresses sustainability risks in its investment decision-making process insofar as relevant. ‘Sustainability risk’ means an environmental, social, or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. When identifying a sustainability risk during the due diligence on potential investments, Robin Capital GmbH decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk. Robin Capital GmbH regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.
Transparency of Adverse Sustainability Impacts
Robin Capital GmbH does not consider principal adverse impacts of investment decisions on sustainability factors. ‘Sustainability factors’ mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. Robin Capital GmbH does not use sustainability indicators.
Considering the numerous legal uncertainties currently related to the application of the provisions of the Sustainable Finance Disclosure Regulation (EU 2019/2088) (EU 2022/1288) and the Regulatory Technical Standards (“RTS”) – in particular with respect to the consideration of adverse impacts – and the administrative burden resulting from such uncertainties, Robin Capital GmbH is not in a position to commit to such standard in light of its fiduciary duty to the fund and its investors. Robin Capital GmbH will constantly monitor and review the evolution around such regulations and standards and considers changing its position on adverse impacts once (i) a best practice has evolved among market participants, (ii) there is clear guidance by the administrations on the application of such regulations and (iii) the consequences of a commitment towards the consideration of principal adverse impacts are reasonably clear to Robin Capital GmbH.
Transparency of Remuneration Policies in Relation to the Integration of Sustainability Risks
As a registered alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB), Robin Capital GmbH does not have and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.
SFDR Statement (2022/1288)
The following disclosure relates to Robin Capital GmbH (LEI: 391200T8Z95JVC8G1M46):
Statement of Principal Adverse Impacts on Investment Decisions on Sustainability Factors
Kindly refer above to the headline ‘Transparency of Adverse Sustainability Impacts’ for the PAI Statement.
The present statement on PAI on sustainability factors covers the reference period from 1 January 2023 to 31 December 2023. The earliest historical comparison will be provided in June 2025.
Date of Publication:
This document was last updated on 04/12/2023 to incorporate amendments and additions from the 2022/1288 SFDR update. If you have any questions, please do not hesitate to contact us at esg@ace-alternatives.com.
