Sustainability risk within the meaning of Regulation (EU) 2019/ 2088 on sustainability-related disclosures in the financial services sector (the “Disclosure Regulation”) may lead to a decrease in the financial value or performance of the Cooperative. For example, sustainability risks may be identified in a portfolio company, which may make it less desirable to future purchasers and consequently have a negative effect on the performance of the Cooperative. The Manager deems ESG factors to be an item in making any decision on an investment and considers ESG factors throughout its investment process. The Manager’s approach to ESG is set out in the Manager’s ESG Policy.

Although the Manager’s ESG Policy has what the Manager believes a strong link and/or overlap with the indicators as defined by the draft Sustainable Finance Disclosure Regulation (the “SFDR”) Regulatory Technical Standards proposed by the European Supervisory Authorities ("RTS"), the Manager does not consider the adverse impacts of investment decisions on sustainability factors as referred to in article 4 of the SFDR for the following reasons:

  • The RTS have only recently been published and these are being reviewed and considered by the Manager at the date of this prospectus.
  • Not all indicators as listed in Table 1 of Annex I of the RTS are relevant for each investment.
  • Not all data for these indicators are available in the level of detail and frequency as required by the RTS.


General information on the remuneration policy of Prime Ventures

Prime Ventures has a remuneration policy. The policy aims to align the interests of identified staff of Prime Ventures with the interests of the investors in the Prime Ventures’ funds and to avoid incentives that could result in excessive risk taking.

Prime Ventures pays to its staff a combination of fixed (salary) and variable (such as bonus) remuneration. Variable remuneration for identified staff takes into account performance criteria including compliance with policies (such as but not limited to the impact of ESG risks on the investment decision making process).

The remuneration policy is adopted by the Board of Management in accordance with the EU Directive 2011/61/EU on AIFMD and the Dutch Act on Financial Supervision (Wet op het financieel toezicht).