Sustainability Related Disclosures

Sustainability related disclosures

Date of last update: June 2024

I. Introduction
BoldMind Capital Partners B.V. (hereafter the “AIFM”), is a Dutch-based registered alternative investment fund manager within the meaning of article 2:66a Dutch Act on financial supervision (Wet op het financieel toezicht).

The AIFM acts as a fund manager for BoldMind Fund I Cooperative U.A. (hereafter the “Fund”).

The AIFM makes the following disclosures for the purposes of Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector (hereafter “SFDR”) and Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (hereafter the “Taxonomy Regulation”).

The AIFM must comply with certain SFDR requirements applicable to registered alternative investment fund managers.
The Fund qualifies under article 6 SFDR as it does not promote environmental or social characteristics, article 8 SFDR, nor it has sustainable investments as it objective as mentioned in article 9 SFDR.

II. Definitions

To understand the disclosures, the SFDR framework applies multiple definitions:

• A “Sustainable Investment” is defined as an investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators on the use of energy, renewable energy, raw materials, water and land, on the production of waste, and greenhouse gas emissions, or on its impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality or that fosters social cohesion, social integration and labor relations, or an investment in human capital or economically or socially disadvantaged communities, provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance.

• “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.

• “Sustainability Factors” mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

III. Sustainability risk integration, article 3 SFDR

The AIFM does not integrate sustainability risk in its investment due diligence processes on the level of the AIFM because the risk cannot be quantified on the level of the portfolio companies.

IV. No consideration of adverse impacts of investment decisions on sustainability factors, article 4 SFDR

The SFDR requires fund managers such as the AIFM to provide a clear statement as to whether or not they consider the “principal adverse impacts” of investment decisions on sustainability factors, e.g. environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
The AIFM, does not consider the adverse impacts of investment decisions on sustainability factors due to:

(i) the fact that this is not part of the investment objectives of the AIFM; and

(ii) the non-availability of the right impact information. If detailed data is available obtaining this information is often expensive and the analysis of it time-consuming, which neither the small organization of the AIFM nor the Fund is willing to bear because of negative effects on returns.

(iii) the performance tools used by the AIFM to estimate returns of the Fund do not take into account such risks but mainly economic and financial risks;

(iv) view of the AIFM size it is not intended to change the investment decision-making process of the AIFM to integrate such sustainability risks as this will be too costly and not relevant with respect to the Fund.

The AIFM does not intend to consider adverse impacts of investment decisions on sustainability factors in the near future as a mandatory investment decision criterium because it will not be part of the investment objectives of the AIFM.

V. Remuneration and sustainability risk, article 5(1) SFDR

Article 5 of SFDR states that AIFM shall include in their remuneration policies, information on how such policies are consistent with the integration of sustainability risks and shall publish that information on its website. AIFM considers sustainability risk is not part of the remuneration policy because sustainability risk is no relevant factor in the investment universe of the Fund as managed by the AIFM.