SFDR

In order to comply with the sustainable finance disclosure regulation (SFDR) (Regulation (EU) 2019/2088), IRIS Investment Club Fondsmanager B.V. (IRIS) makes the following disclosures.

Integration of sustainability risks

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”.

Before any investment decisions are made on behalf of a fund that IRIS manages, an investment decision process is followed which in regard to specific investments includes the approval of the investment committee of such fund. IRIS views ESG as a standard topic in the pre-investment process. Part of the investment decisions process is that IRIS assesses the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are considered by IRIS when making investment decisions. 

Remuneration policy

IRIS pays staff a combination of fixed remuneration and variable remuneration (including a possible bonus). Variable remuneration for relevant staff also takes into account compliance with all policies and procedures which are in effect within IRIS, including those relating to sustainability risks on the investment decision making process.

No consideration of sustainability adverse impacts

In accordance with article 4 sub 1 (b) of the SFDR, IRIS states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the SFDR. Therefore, IRIS does not make the disclosures as described in article 4 sub 1 (a) of the SFDR (PAI Statement) based on considerations of proportionality and confidentiality.

At this stage IRIS does not consider the adverse impacts of its investment decisions on sustainability factors, Firstly, IRIS is not obliged to publish a PAI Statement because it has fewer than 500 employees. Secondly, taking into account sustainability factors in accordance with the SFDR requires data from all portfolio companies on a substantial number of indicators as set forth in Annex I to Delegated Regulation 2022/1288 (i.e. SFDR Delegated Regulation). Portfolio companies may not always have access to such data available, and gathering such data could impose significant burdens on the portfolio companies. Furthermore, the preparation of a PAI Statement requires significant time and resources of IRIS, which puts an excessive burden on IRIS’ small organization.

IRIS reviews annually whether it intends to publish a PAI Statement. However, IRIS currently has no intention to do so in the near future.