SFDR
Sustainable Finance Disclosure Regulation (2019/2088) (the "Disclosure Regulation").
LSP Advisory B.V (“LSP” or “the Manager”), makes the following disclosures in accordance with Articles 3(1), 4(1)(a) and 5(1) of the Disclosure Regulation.
Sustainability risk policies
A sustainability risk means "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 the investment". For LSP, sustainability risks are risks which, if they were to crystallize, would cause a material negative impact on the value of the portfolio of one or more of its alternative investment funds (AIFs).
Before any investment decisions are made on behalf of an AIF that LSP manages, LSP completes a process that identifies the material risks associated with each proposed investment; these will include relevant and material sustainability risks.
LSP considers these risks as part of its risk management process for the funds it manages, starting with an overall assessment of the likely risks associated with investments pursuant to the relevant fund’s investment policy and objectives and leading to specific investment proposals submitted to the investment committee.
The investment committee assesses all the identified risks, including sustainability risks alongside other relevant factors set out in the proposal. Following its assessment, the investment committee makes investment decisions having regard to the relevant fund's investment policy and objectives. Throughout the entire process, relevant sustainability risks are identified and assessed using the same process as is applied to other relevant risks affecting the funds and investments made on their behalf.
Remuneration policy
LSP pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff takes into account compliance with all policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process. The variable remuneration is set so that the structure of remuneration does not encourage excessive risk taking, including with respect to direct or indirect sustainability risks.
Principal Adverse Impact reporting
Pursuant to article 4 sub 1(b) of the SFDR, and at the date of this disclosure, the Manager does not consider principal adverse impacts on sustainability factors as the relevant data for measuring such impact is not yet available to a sufficient extent, particularly in relation to the type of early stage companies in which the Fund invests, as well as investments in publicly listed companies and/or portfolio companies domiciled outside the European Union. Additionally, given the size of LSP, such disclosures would not be proportional. The Manager continues to closely monitor the evolution of the market and regulatory landscape in relation to consideration of adverse impacts on sustainability factors. Whether the Manager will consider principal adverse impacts on sustainability factors will be assessed at least annually by the Manager.
Additionally, sustainability impact is considered during the screening and due diligence phases of proposed investments. LSP, in line with the strategy defined at EQT group level and as further described in the EQT RI&O Policy (available online), avoids investing in cases where the products, services, or practices cause environmental or social harm and where there is no transition pathway to mitigate such negative impacts through active ownership. In line with the aforementioned strategy, LSP aims to promote sustainable business solutions and practices in the investments that the LSP funds own or have an interest in through its focused approach on equitable business practices and accountable leadership - with its overarching commitment to fostering life.
Product-specific sustainability disclosures
Product-specific sustainability disclosures are available on the investor portal for relevant funds.