Sustainable Finance Disclosure
FIRM LEVEL WEBSITE DISCLOSURE (ARTICLE 3, 4 AND 5 SFDR)
Avedon Capital Partners B.V. (Avedon) makes the following disclosures in accordance with articles 3(1), 4 (1) (b) 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 Avedon, sustainability risks are risks which, if they were to crystallise, would cause a material negative impact on the value of the portfolios of its alternative investment funds (AIFs).
Before any investment decisions are made on behalf of an AIF, Avedon follows an investment process consisting of various phases, namely a preliminary investment (PIP) phase, a due diligence (Due Diligence) phase and a final investment proposal (FIP) phase. During the PIP phase high importance ESG issues are assessed and reported (e.g., exclusion list activities, high risk ESG activities such as exposure to countries with poor labour conditions or low environmental standards). During the Due Diligence phase, a thorough review of ESG issues is made. The scope of the ESG Due Diligence is amended each time to include the elements that are material to the target’s business. In the FIP the investment team will highlight any material ESG issues that were discovered during the due diligence process. The FIP should include an assessment of the commitment, capacity, and track-record of target’s management to deal with material ESG issues. The AIF’s Investment Committee is responsible for decision-making and whether to (conditionally) accept material ESG risks.
Avedon pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff considers compliance with all policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process.
NO CONSIDERATION OF SUSTAINABILITY ADVERSE IMPACTS
In accordance with article 4 sub 1 (b) of the Disclosure Regulation, Avedon states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the Disclosure Regulation. Given the small size of the organisation of Avedon, such disclosure as set forth in article 4 sub 1 (a) of the Disclosure Regulation and the administrative burden in connection therewith would not be proportional.