Article 3 - Integration of sustainability risks

In accordance with article 3 of SFDR, SNÖ Ventures is required to disclose on its website its policies on the integration of sustainability risks in its investment decisions.

Sustainability risk is defined as 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 an investment.

Assessment of sustainability risks is an integral part of SNÖ Ventures’ due diligence and decision-making process when evaluating potential investments. Such assessment is being conducted by inter alia review of the company’s activities and discussions with management.

The results from the due diligence process, including information on material sustainability risks, are included in SNÖ Ventures’ investment documentation that underlie the final investment decision. If the identified sustainability risks are deemed to be too high in relation to investing in a company, SNÖ Ventures will refrain from investing.

SNÖ Ventures will not invest in certain predefined industries considered to be inherently exposed to sustainability risk. This includes inter alia businesses relating to tobacco and alcohol, narcotics substances, weapons, gambling, pornography, coal and oil sands and businesses contributing directly or indirectly to human rights violations, corruption, bribery and severe environmental degradation.

Article 4 - No consideration of adverse sustainability impacts

In accordance with article 4 of SFDR, SNÖ Ventures is required to disclose on its website whether or not principal adverse impacts of investment decisions on sustainability factors are taken into account.

SNÖ Ventures currently does not take into account principal adverse impacts of its investment decisions on sustainability factors within the meaning of SFDR.

The reporting requirements that apply when taking into account principal adverse impacts would necessitate extensive data collection and validation. Further, due to the nature of our investments (early-stage digital tech companies) the principal adverse impact indicators are considered not relevant for the majority of our portfolio companies at the time of our investment. The portfolio companies are also expected to not have precise data of a sufficient quality readily available. As such, SNÖ Ventures does not consider the implementation of required data collection, validation and reporting requirements to be proportionate with the anticipated impacts of taking principal adverse impacts into account.

SNÖ Ventures may opt to change its position in the future.

Article 5 - Transparency of remuneration policies in relation to the integration of sustainability risks  

In accordance with article 5 of SFDR, SNÖ Ventures is required to disclose on its website information on how the remuneration policy is consistent with the integration of sustainability risks in the decision-making process.

As a registered (“sub-threshold”) AIFM, SNÖ Ventures has not adopted a remuneration policy pursuant to the Alternative Investment Fund Manager Directive, and no employees in SNÖ Ventures with decision-making authority receive variable remuneration. As such, SNÖ Ventures is of the view that there are no misalignments between their remuneration practices and the integration of sustainability risks in the decision-making process.