Duurzaamheidsbeleid
In accordance with the SFDR and the Taxonomy Regulation, Van Druten Capital B.V., as the manager of investment funds, is required to provide information on sustainability in relation to the funds it manages. This section provides the necessary information regarding the Units.
Qualification of Units
The funds of Van Druten Capital B.V. do not promote environmental or social characteristics (‘light green investments’ as referred to in Article 8 of the SFDR) and do not have sustainable investments as their objective (‘dark green investments’ as referred to in Article 9 of the SFDR). The underlying investments of these financial products do not take into account the EU criteria for environmentally sustainable economic activities.
Policy on sustainability risks
Van Druten Capital B.V. acknowledges that the realization of sustainability risks can potentially negatively impact the value of investments. In brief, a sustainability risk is an event within the environmental, social, or governance (ESG) domains that could adversely affect the value of the Units. For example, sustainability risks in the environmental domain include CO2 emissions, energy consumption, and biodiversity loss. In the social domain, sustainability risks may involve product liabilities and respect for human rights. In governance, sustainability risks may include inclusivity and diversity, compensation, and corporate ethics. Van Druten Capital B.V. integrates sustainability risks to a limited extent in investment decisions. This section describes how sustainability risks are identified and integrated into investment decisions. Specific sustainability risks identified by Van Druten Capital B.V. regarding its funds are detailed in section 6.2 of the Investment Memorandums of the funds of Van Druten Capital B.V.
Unfavorable effects of investment decisions on sustainability factors not considered
Van Druten Capital B.V. does not consider the adverse effects of investment decisions on sustainability factors and therefore does not annually prepare a so-called Principal Adverse Sustainability Impact statement (PAI). Taking into account the adverse effects of investment decisions on sustainability factors would require Van Druten Capital B.V. to report on this matter. The necessary information for reporting is currently not available within Van Druten Capital B.V. Obtaining such information would necessitate Van Druten Capital B.V. to undertake (costly) measures. Van Druten Capital B.V. considers this to be disproportionate, especially since investors are not expected to attach significance to a PAI. The foregoing does not preclude Van Druten Capital B.V. from reconsidering the decision not to account for adverse effects of investment decisions on sustainability factors, should relevant circumstances arise. For instance, if the majority of investors request a PAI.
Sustainability risks and remuneration policy
Under the AIFMD registration regime, Van Druten Capital B.V. is not obligated to adhere to the legally prescribed remuneration policy. Given the limited size of the organization, it was decided not to (voluntarily) establish a specific remuneration policy. Due to the absence of (an obligation to establish) a remuneration policy, the SFDR requirement regarding the provision of information about the remuneration policy and the extent to which that policy aligns with sustainability risks does not apply to Van Druten Capital B.V.
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