Sustainability
Above Capital
No consideration of adverse impacts of investment decisions on sustainability factors
The European Union has introduced a series of legal measures, the primary one being the Sustainable Finance Disclosures Regulation (EU Regulation 2019/2088) of the European Parliament and of the Council of November 27, 2019 on sustainability-related disclosures in the financial services sector, requiring firms that manage investment funds and other collective investment schemes to provide transparency on how they integrate sustainability considerations into the investment process with respect to the Funds and schemes they manage. This legislation was subsequently supplemented and amended by (i) EU Regulation 2020/852 of June 18, 2020 (“Taxonomy Regulation”) and (ii) EU Regulation 2022/1288 of April 6, 2022 (“Regulatory Technical Standards” or “RTS”).
Above Capital conduct is based on certain principles, including responsible investment, recognizing the existence of potential environmental and social risks that may arise from its Funds investments. Furthermore, the Company supports the initiatives on transparency and incorporation of sustainability risks included in the SFDR, and the RTS, and is aligned with the objectives that these regimes aim to achieve.
According to Article 2, paragraph 22, of the SFDR, a sustainability risk means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.
Above Capital doesn’t meet the requirements applicable to large financial institutions, enshrined in Article 4 (paragraphs 3 and 4) of the above-mentioned EU Regulation 2019/2088 (“SFDR”), and the Funds currently registered by the company fall within the scope of Article 6 of this same Regulation.
In reference to Article 10 of the SFDR, Above Capital doesn’t market or manage Funds that promote, among others, environmental or social characteristics, or a combination of these characteristics (provided for in Article 8 of the SFDR), nor Funds that aim at sustainable investments (provided for in Article 9 of the SFDR).
In compliance with Article 4, paragraph 1, subparagraph b) of the SFDR, Above Capital herein declares that it does not take into consideration the adverse impacts of investment decisions on sustainability factors.
This occurs because, at this stage, the investments to be made by the Company´s Funds are expected to be in small and medium sized companies, that typically have insufficient sustainability information and limited resources, and thus unable to cope with high and disproportionate costs related to sustainability issues. Moreover, Above Capital itself, at this stage, is unable to obtain satisfactory sustainability information, e.g. from third parties, because of the costs that this would imply for the Company.
Nevertheless, the Company will on principle seek to consider publicly available information on the ecological and social impact, exposure to fossil fuels, water consumption or energy efficiency in the sectors in which its Funds invest. This information will be considered on a case-by-case basis, in compliance with the mandates given in the Funds Regulations, thus seeking the development of sustainability practices and principles in the companies the Funds will invest into.
Since the context of this matter is constantly evolving, Above Capital will continuously reassess and improve its position over time, whenever justified, and is certain that in the future there will be a moment in which it will reinforce its commitment towards sustainability, together with all stakeholders, and start taking into account the potential adverse impacts of its investment decisions regarding sustainability factors, mainly by incorporating these risks into its policies and decision-making process.
Since Above Capital registered Funds are yet to undertake their first investments, we are unable to, at this time, predict with accuracy the scope and the moment in which this improvements might occur.
Because of all of the above-stated, mainly the stage in which Above Capital and its Funds are at, currently the Company’s remuneration policy doesn’t consider the integration of sustainability risks.
All information published on Above Capital website regarding sustainability is permanently updated, and any changes or amendments will be duly published, as required by the SFRD.
Last updated: July 5th, 2024