DISCLOSURES REQUIRED UNDER THE SUSTAINABLE FINANCE DISCLOSURE REGULATION
This statement presents information to comply with Smile Invest’s legal obligations regarding investor information, especially regarding Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability reporting in the financial services sector ("SFDR").
Smile Invest may update this statement at any time.
Article 3 Disclosure - Transparency of sustainability risk policies
Policies on the integration of sustainability risks in the investment decision‐making process
Smile Invest considers sustainability risks in its investment decision-making process through the process described below. Sustainability risks are potential risks linked to an environmental, social or governance event that is likely to negatively impact the relevant portfolio companies’ value.
- An exclusion list, that excludes companies that may represent sustainability risks in terms of sectors and countries.
- A Sustainability pre-investment analysis that assesses sustainability risks. The outcome of this assessment is presented in a dedicated Sustainability section of the investment note, and is discussed at the investment committee. If significant sustainability risks are identified, mitigating actions are integrated in the Sustainability roadmap and objectives of the relevant portfolio companies.
- An annual reporting and monitoring of the portfolio companies is conducted to assess the potential sustainability risks.
More information regarding the investment process described above can be found in the Sustainability Policy.
Article 4 Disclosure – Transparency of adverse sustainability impacts at entity level
Smile Invest does not consider adverse impacts of investment decisions on sustainability factors. Indeed, Smile Invest takes into account its own Sustainability criteria in its investment decisions (as described in the Sustainability Policy), as they provide a more tailored approach to Smile Invest’s investment opportunities and portfolio companies.
This position may however be revised and changed at a later date.
Article 5 Disclosure - Transparency of remuneration policies in relation to the integration of sustainability risks
Smile Invest’s remuneration policy does not formally include sustainability criteria. Respect of sustainability processes is however implicitly included, as it is part of the investment process that investment teams should follow, and which is qualitatively included in investment teams’ bonus assessment.