Sustainable Risk Finance Disclosure Regulation (2019/2088) (the Disclosure Regulation)
Gilde Healthcare Partners B.V. (GHP) makes the following disclosures in accordance with articles 3(1) 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 GHP, sustainability risks are risks which, if they were to materialize, 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, GHP completes a process that aims at identifying the material risks associated with each proposed investment; these will include relevant sustainability risks.
The investment advisory committees of GHP aim to assess the identified risks alongside other relevant factors set out in an investment proposal. Following its assessment, the relevant investment advisory committee advises on the investment having regard to the relevant AIF's investment policy and objectives. The board of directors of GHP resolves upon investment decisions taking into consideration the advice of the investment advisory committees. It is the intention that throughout the entire process, relevant sustainability risks are identified and assessed using the same process as is applied to other relevant risks affecting the AIFs and investments made on their behalf.
GHP pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff takes into account performance criteria including compliance with all policies and procedures (e.g. relating to the impact of sustainability risks on the investment decision making process).
No consideration of sustainability adverse impacts
With due observance of article 4 sub 1 (b) of the SFDR, GHP declares that it currently does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the SFDR and therefore does not make the disclosures as described in such article. Given the size and scale of the activities of GHP these considerations and disclosures would not be proportional. Besides the proportionality, the regulatory technical standards as referred to in article 4 sub 6 and 7 of the SFDR which provide for the content, methodologies and presentation of such disclosures have not yet entered into force. GHP will reconsider whether it will or should make disclosures on the adverse impacts of its investment decisions on sustainability factors in the manner as set forth in article 4 sub 1 (a) of the SFDR once these regulatory technical standards have entered into force.