Sustainability Related Disclosures
Kadera Capital Management GmbH (“Kadera Capital”) is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (“SFDR”).
Art. 3 SFDR – Sustainability risk policies statement
Kadera Capital addresses sustainability risks in its investment decision-making process insofar as relevant. “Sustainability risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. During the due diligence on potential investments, Kadera Capital conducts a careful analysis of the investment's exposure to environmental, social, and governance risks that could impact its value. When identifying a sustainability risk during the due diligence on potential investments, Kadera Capital decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk. Kadera Capital regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.
Art. 4 SFDR – No consideration of principal adverse impacts
Kadera Capital does not consider principal adverse impacts of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. Kadera Capital does not use sustainability indicators. The standardized catalog of Key Performance Indicators (KPIs) provided by Annex I of the regulatory technical standards (RTS) issued under the Sustainable Finance Disclosure Regulation (SFDR) is not tailored to the specific needs of the. Kadera Capital investment strategy
In many instances, data will be insufficient for analyzing PAI, and on occasions where data is obtainable, it tends to offer little in terms of comparability and fails to provide additional insights for Kadera Capital. Therefore collecting data on PAI will not only increase the administrative burden and costs but also fail to provide a new perspective for Kadera Capital.
Art. 5 SFDR – Remuneration Disclosure
As a registered alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB), Kadera Capital does not have and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.
Art. 10 SFDR – Sustainability-related information about financial products that promote environmental or social characteristics
Kadera Capital Management GmbH (“Kadera Capital”) is the alternative investment fund manager of Kadera Focus I GmbH & Co. KG (“Kadera Focus I”) within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (“SFDR”).
Summary
This financial product promotes environmental or social characteristics but does not have as its objective a sustainable investment. The promoted characteristics are investment restrictions. 100% of the investments will be in line with its investment strategy and investment restrictions.
No reference benchmark has been designated to attain the environmental or social characteristics promoted by the financial product.
Zusammenfassung
Dieses Finanzprodukt bewirbt ökologische oder soziale Merkmale, strebt aber keine nachhaltigen Investitionen im Sinne der Definition des Art. 2 Nr. 17 SFDR an. Bei den beworbenen Merkmalen handelt es sich um Ausschlusskriterien. 100 % der Investitionen werden im Einklang mit der Anlagestrategie und den Anlagebeschränkungen getätigt.
Es wurde kein Referenzwert benannt, um die mit dem Finanzprodukt beworbenen ökologischen oder sozialen Merkmale zu erreichen.
No sustainable investment objective
This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment.
Environmental or social characteristics of the financial product
The promoted characteristics of this product are investment restrictions.
Kadera Focus I GmbH & Co. KG may not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies or other entities whose business activity consists of an illegal economic activity (i.e., any production, trade or other activity which is illegal under the laws or regulations applicable to the Partnership or the relevant company or entity, including without limitation, human cloning for reproduction purposes), or which substantially focus on the production of or trade in tobacco or distilled alcoholic beverages, the production of or trade in weapons or ammunition of any kind (it being understood that this restriction does not apply to the extent such activities are part of or accessory to explicit European Union policies), or the research, development or technical applications relating to electronic data programs or solutions, which aim specifically at supporting any aforementioned activity, or pornography, or which are intended to enable to illegally enter into electronic data networks or to illegally download electronic data. 100% of the investments will be in line with its investment strategy and investment restrictions.
Investment strategy
The purpose of the Partnership is to build, hold and manage in its own name and for its own account a portfolio of equity and quasi-equity investments in late-stage technology companies primarily in Europe and the U.S.
No investments are made in the area of exclusions. As part of the due diligence and ongoing investment management, the investment team for the Partnership will initially and continuously monitor whether the investment restrictions are abided by and whether the investment falls within the investment policies.
Policy to assess good governance practices of the investee companies
As part of the due diligence and ongoing investment management, the investment team will review whether a potential investee company has good governance practices in place. This might include using ESG (environmental, social, and governance) criteria to evaluate companies' performance in areas such as labor practices, human rights, and corporate governance, conducting due diligence on investee companies to assess their management structures, employee relations, and tax compliance, engaging with investee companies through to encourage improvements in governance practices if necessary. The intensity of the assessment is carried out in accordance with the principle of proportionality. Where the manager sees higher risks of a non-compliance, they will intensify the audit.
Proportion of investments
Kadera Focus I will invest fully in line with its investment strategy and investment restrictions. Kadera Focus I will not invest a portion of its capital in any other asset class.
Monitoring of environmental or social characteristics
The investment team for Kadera Focus I will initially and continuously monitor whether the investment restrictions are abided by and whether the investment falls within the investment policies. Kadera Focus I will not make any investment in the excluded sectors unless previously approved by the advisory committee. Therefore, the achievement of the promoted ESG aspects – no investment within the excluded sectors – can be tracked in a simple way.
Methodologies for environmental or social characteristics
See above. The exclusion list is used to measure how the social or environmental characteristics promoted by the financial product are met.
Data sources and processing
Kadera Focus I receives data provided by the portfolio companies as part of the due diligence process and at regular intervals after the investment. Where necessary or beneficial, Kadera Focus I also makes use of publicly available data. Data processing is exclusively internal and DSGVO compliant. Estimates of data are not made.
Limitations to methodologies and data
Kadera Capital is partly reliant on the information provided by portfolio companies during the due diligence process. Moreover, in the post-investment phase, Kadera Capital is reliant on the company’s reported data. In both cases, complete data may not always be available due to the nature of the investments. The information is verified only if and to the extent misrepresentations are suspected.
Since Kadera Focus I’s investments are made for a multi-year investment period, Kadera Capital places a high priority on establishing a trusting working relationship with the portfolio companies to ensure that data is submitted reliably and completely and that the above restrictions are met.+
Due Diligence
Kadera Capital considers the promoted ESG aspects when sourcing new portfolio companies for Kadera Focus I and during the due diligence on targeted portfolio companies. The due diligence is performed by obtaining all information relevant to Kadera Focus I using a due diligence questionnaire, which is then reviewed internally. If necessary, further specific information is also obtained from the potential portfolio companies, should this still be necessary after the detailed questioning. The due diligence process is not monitored externally.
Engagement policies
Kadera Focus I invests in the portfolio companies for a period of several years. Therefore, Kadera Capital makes it a priority to establish and maintain a trusting working relationship with the portfolio companies in order to continuously comply with the investment restrictions. Kadera Capital thus also intends to establish or strengthen the consideration of sustainability risks at the portfolio level. Kadera Capital is in constant dialogue with the portfolio companies, but as a venture capitalist without majority ownership, the influence Kadera Capital can exert on the portfolio companies is limited.
Last Version: October 15, 2024