Sustainability-related disclosures under the SFDR for Rite Ventures
Introduction
Rite Ventures Management AB (the “Manager”, or “Rite Ventures”) is a sub-threshold alternative investment fund manager registered in accordance with the Swedish act on alternative investment fund managers (Sw. lag om förvaltare av alternativa investeringsfonder) (“LAIF”). The Manager manages the alternative investment fund, Rite Internet Ventures Holding AB (the “Fund”).
This information is disclosed in accordance with Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR”) and Commission Delegated Regulation (EU) 2022/1288, which supplements Regulation (EU) 2019/2088 of the European Parliament and the Council. The RTS sets out regulatory technical standards detailing the content and presentation requirements for information related to the principle of ‘do no significant harm,’ sustainability indicators, adverse sustainability impacts, and the promotion of environmental or social characteristics, as well as sustainable investment objectives. These disclosure requirements apply to pre-contractual documents, websites, and periodic reports.
Integration of sustainability risks into Rite Ventures´ investment process
A “Sustainability Risk” is an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment, and hence the net asset value of the Investment Company. Sustainability Risks include environmental risks, social risks and governance risks.
Rite Ventures integrates sustainability risks into its investment decision-making process. These risks include environmental, social, and governance (ESG) factors that could potentially have a material adverse impact on an investment’s value. As part of its due diligence process, Rite Ventures assesses sustainability risks before making any investment. This evaluation is conducted through a case-by-case approach, based on the specific circumstances of each opportunity. The findings of this assessment are considered when making investment decisions. Rite Ventures retains the discretion to proceed with or refrain from an investment despite identified sustainability risks. Where necessary, measures may be applied to reduce or mitigate such risks. Rite Ventures follows the principle of proportionality, carefully balancing sustainability considerations with the strategic relevance and transactional context of each investment.
Renumeration disclosures
As a registered alternative investment fund manager, the Manager are not required to have a remuneration guideline or policy in accordance with the requirements of LAIF.
No consideration of adverse impacts of investment decisions on sustainability factors
Adverse impacts on sustainability factors refers to negative impacts on environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.
Currently, the Manager does not consider the principal adverse impacts of investment decisions on sustainability factors. The Manager has decided not to consider principle adverse impacts of such purposes because:
- the Manager is a registered sub-threshold alternative investment fund manager that has recently been granted its registration and has a small organization. Given the small size of the organization, such measurements, reporting and other actions to meet the optional disclosure requirement would currently not be proportional; and
- Moreover, the Fund will mainly hold minority positions in its portfolio companies. Such minority interests are, however, generally not sufficient to enforce the Fund’s portfolio companies to collect and provide the relevant data.
The decision not to make the periodic comparison or publish information on the planned actions or target setting relating to the next reference period in relation to the principal adverse impacts under SFDR articles 4 and the SFDR Delegated Regulation may be reviewed when the market practice relating to the SFDR and the data and the tools for measuring and comparing the adverse impacts on sustainability indicators under SFDR Delegated Regulation Annex I have been more developed and become more efficient, and the organization of the Manager as a regulated entity has matured.