1. INTEGRATION OF SUSTAINABILITY RISKS
The EU Sustainable Finance Disclosures Regulation (2019/2088) on sustainability-related disclosures in the financial services sector (the “SFDR”) defines “sustainability risks” as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment. Frontline Ventures Management Company Limited (together with any relevant delegate, the “Manager”) has integrated sustainability risks, as a sub-set of risks generally that could cause an actual or potential material negative impact on the value of an investment, as part of its investment decision-making process for Frontline Venture Fund I L.P, Frontline Venture Fund II L.P, Frontline Venture Fund III L.P., Frontline EMEA Expansion Fund I L.P. and Frontline EMEA Expansion Fund II L.P. (each a “Fund” and together the “Funds”). The ESG factors taken into account are further described in its ESG policy. If appropriate for an investment, the Manager may conduct sustainability risk-related due diligence and/or take steps to mitigate sustainability risks and preserve the value of the investment. Further detail is included in our ESG policy.
The identification and assessments of risks, including sustainability risks, will take place on an investment-by-investment basis. The Manager’s assessment is that integration of known sustainability risks in investment decisions should help mitigate the potential material negative impact of sustainability risks on the returns of the Funds, although there can be no assurance that all such risks will be mitigated in whole or in part, nor identified prior to the date the risk materialises.
2. NO CONSIDERATION OF SUSTAINABILITY ADVERSE IMPACTS
Notwithstanding the fact that the Manager considers sustainability risks that could cause an actual or potential material negative impact on the value of an investment, the Manager does not consider the adverse impacts of its investment decisions for the Funds on sustainability factors, within the meaning of Article 4(1)(a) of the SFDR, for the time being. The Manager does not currently do so because the Manager is not, in its view, currently in a position to obtain and/or measure all the data which it would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost with respect to all their investment strategies to clients and investors. This is in part because underlying investments are not widely required to, and may not currently, report by reference to the same data. The Manager’s position on this matter will be reviewed at least annually.
The Manager’s remuneration policy or other remuneration arrangements relating to its staff takes into account compliance with its policies and procedures related to the integration of sustainability risks in its investment decision-making process.