Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088
The following information contains sustainability-related disclosures from aws Fondsmanagement GmbH, FN 327045 z, ("FMG") in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosure requirements in the financial services sector (in its applicable version, the "Disclosure Regulation").
Strategies for handling sustainability risks
According to the Disclosure Regulation, "sustainability risks" refer to events or conditions in the areas of environment, social, or governance, whose occurrence could actually or potentially have significant negative impacts on the value of the investment. The investment decision processes relating to aws Gründungsfonds II Beteiligungs GmbH & Co KG ("AWS GRF II") generally do not involve a targeted or systematic consideration of sustainability risks within the meaning of the Disclosure Regulation. However, FMG, as the general partner of AWS GRF II, will continuously monitor both actual and potential significant negative impacts of sustainability risks on investment decisions, as well as on the assets, financial situation, and profitability of AWS GRF II as part of its general risk management.
FMG further intends, as part of its portfolio management activities, to support portfolio companies in complying with their ESG policies. If sustainability-related information (such as through a questionnaire) is collected during due diligence reviews or general risk management of (potential) portfolio companies, this information will generally not be externally verified, nor will FMG conduct further investigations or research. It cannot, therefore, be completely ruled out that in some cases false information may go undetected. Since AWS GRF II invests over several years, it is important to FMG to establish and maintain a relationship of trust with the portfolio company in the course of good cooperation to protect itself from the limitations described in this section.
AWS GRF II does not pursue sustainable investments within the meaning of Article 2 (17) of the Disclosure Regulation. Specifically, AWS GRF II does not invest a fixed percentage in portfolio companies aligned with ecological and/or social criteria (more information can be found in the investment guidelines of AWS GRF II). FMG remains free to decide, at its discretion, not to invest or to invest despite sustainability risks, in which case FMG may also take measures to reduce or mitigate sustainability risks. FMG intends to apply the principle of proportionality and appropriately consider the strategic relevance of an investment and the transaction context.
Statement on adverse sustainability impacts
Since the business model of early-stage target companies is often not fully developed, sustainability risks and the most significant adverse impacts of FMG’s investment decisions on sustainability factors are often difficult to assess. "Sustainability factors" are understood, according to the Disclosure Regulation, as environmental, social, and employee matters, respect for human rights, and the fight against corruption and bribery. Given the investment focus of AWS GRF II, FMG does not commit to considering the adverse impacts of investment decisions on sustainability factors (which makes Article 4 (1) lit b) of the Disclosure Regulation applicable to FMG). However, FMG may, on a case-by-case basis, assess and consider the most significant adverse impacts of its investment decisions on sustainability factors before and after an investment during due diligence reviews or general risk management. In any case, FMG remains free to decide, at its discretion, not to invest or to invest despite adverse impacts on sustainability factors, in which case FMG may also take measures to reduce or mitigate adverse impacts. FMG intends to apply the principle of proportionality and appropriately consider the strategic relevance of an investment and the transaction context.
Remuneration policy
FMG does not take sustainability risks into account in its remuneration policy.