Sustainability-related disclosures (date of publication 1 March 2023)
On 10 March 2021, the Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088; the SFDR) came into force in the Netherlands. This European Regulation requires certain financial market participants (such as managers of alternative investment funds) to publish sustainability-related information on their website and in pre-contractual disclosures.

The SFDR lays down harmonised rules for financial market participants (such as managers for alternative investment funds) on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes. In addition, financial market participants are required to provide sustainability-related information with regard to the funds that they manage.

In the following you can read more about the manner in which Fiedler Capital Fund Management B.V. takes sustainability-related aspects into account when making investments.

No consideration of adverse impacts of investment decisions on sustainability factors
Fiedler Capital Fund Management B.V. does not integrate sustainability risks in its investment decision-making process. Fiedler Capital Fund Management B.V. has chosen to do so because the administrative burden would currently have a disproportional impact on Fiedler Capital Fund Management B.V.’s organisation to adequately integrate sustainability risks into the investment decisions-making process.

No adverse sustainability impacts at the level of Fiedler Capital Fund I C.V.
Sustainability risk can have a negative effect on investments. In addition, investments can also have a negative effect on sustainability factors. Sustainability factors are factors that relate to environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. For example, investments can (indirectly) contribute to climate change, waste production or income inequality. Fiedler Capital Fund Management B.V. does not yet consider such principal adverse impacts of investment decisions on sustainability factors with respect to Fiedler Capital Fund I C.V. It has chosen to do so because the administrative burden would currently have a disproportional impact on Fiedler Capital Fund Management B.V.’s organisation to adequately analyse these principal adverse impacts and integrate them into the investment decisions-making process.

Fiedler Capital Fund Management B.V. periodically reconsiders its decision not to take principal adverse impacts of investment decisions on sustainability factors with respect to Fiedler Capital Fund I C.V. It may decide in the future to take into account principal adverse impacts of investment decisions on sustainability factors.

Transparency of remuneration policies in relation to the integration of sustainability risks
The remuneration policy of Fiedler Capital Fund Management B.V. does not take into account sustainability risks.
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