P3A Ventures – SFDR Disclosure Website
P3A Ventures Management GmbH (“P3A Ventures”) is an alternative investment fund
manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch,
KAGB) and as such publishes the following information in light of the consideration of
sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European
Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements
in the financial services sector (“SFDR”).
Art. 3 SFDR – Sustainability risk policies statement
P3A Ventures addresses sustainability risks in its investment decision-making process if and
to the extent 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 of the Partnership. Considering the Partnership’s investment
strategy, P3A Ventures expects sustainability risks not to be relevant in most cases. Where
relevant, P3A Ventures will apply reasonable efforts to appropriately assess such risks and
their potential impacts. P3A Ventures regularly reviews its policies to ensure that they address
new and emerging risks as well as investors’ concerns.
Art. 4 SFDR – No consideration of principal adverse impacts
P3A Ventures 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. P3A Ventures does
not use sustainability indicators. Considering the numerous legal uncertainties currently related
to the application of the provisions of the SFDR and the Regulatory Technical Standards
(“RTS”) – in particular with respect to the consideration of adverse impacts – and the
administrative burden resulting from such uncertainties, P3A Ventures is not in a position to
commit to such standard in light of its fiduciary duty to the fund and its investors. P3A Ventures
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 P3A Ventures.
Art. 5 – Renumeration Disclosure
As a registered alternative investment fund manager within the meaning of the German
Investment Code (Kapitalanlagegesetzbuch, KAGB), P3A Ventures 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.