SFDR Disclosures
SFDR Disclosures – Market One Capital II GP SARL and Market One Capital II, SCSp
07/09/2022
MarketOne Capital II GP SARL (the AIFM), a Luxembourg-based registered alternative investment fund managerwithin the meaning of article 3(2)(b) of Directive 2011/61/EU of 8 June 2011 onalternative investment fund managers (AIFMD), makes the following disclosures for the purposes of Regulation (EU)2019/2088 of 27 November 2019 on sustainability‐related disclosures in thefinancial services sector (SFDR) and Regulation (EU) 2020/852 of 18 June 2020 on the establishment of aframework to facilitate sustainable investment (the TaxonomyRegulation).
TheAIFM acts as registered alternative investment fund manager of Market OneCapital II, SCSp (the Fund).
I. AIFM-relateddisclosures
Transparencyof sustainability risk policies – article 3(1)
General overview
A sustainability risk refers to an environmental,social or governance (ESG) event or condition that, if it occurs, couldcause an actual or a potential material negative impact on the value of aninvestment.
The AIFM reviews and assesses potential sustainability risks within themeaning of SFDR as part of its decision-making process and ongoing riskmonitoring with respect to investments made or to be made by the Fund and hasintegrated such review within its internal procedures and policies, as further detailedhereafter.
Relevance of sustainability risks
Sustainability risks may affect the Fund’s performance having regard tothe types of investments made or to be made in accordance with its investmentpolicy and objectives, meaning that if any such risk occurs, returns oninvestments may be materially negatively affected as a result. Investors andpotential investors should note that it is difficult to assess with reasonablecertainty the probability of the occurrence of such risks and the likely impactof such materialized sustainability risks on the value of investments.
Assessment process and ESG Policy
The identification and assessment of risks, including sustainabilityrisks, will take place on an ongoing basis if and when investments are made inaccordance with the Fund’s investment policy and the ESG Policy (as definedbelow). Such review is performed by the AIFM along with Ślusarczyk i Wspólnicys.k., (the Investment Adviser)], as summarized below:
· Prior to an investmentdecision being taken on behalf of the Fund, the AIFM and the Investment Adviseridentifies the material risks, including sustainability risks, associated with theproposed investment;
· These risks form part of theoverall investment proposal to be submitted to the Investment Committee (asdefined in the limited partnership agreement governing the Fund) by the AIFM;
· Ultimately and following itsassessment, the AIFM makes the relevant investment decision having regard tothe Fund's investment policy and objectives and subject to the InvestmentCommittee’s approval.
The identification, assessment and, to the extent possible, mitigation ofsustainability risks is embedded into the above process through theimplementation of the AIFM’s ESG internal policy (the ESG Policy),available here.
Noconsideration of adverse impacts of investment decisions on sustainabilityfactors – article 4(1)(b)
Article 4(1) of the SFDR requires fund managers such as the AIFM to providea clear statement as to whether or not they consider the "principaladverse impacts" of investment decisions on sustainability factors, i.e.environmental, social and employee matters, respect for human rights,anti-corruption and anti-bribery matters.
Although ESG and sustainability risks are important to the AIFM, the latterdoes not consider the adverse impacts of investment decisions on sustainabilityfactors in the manner prescribed by article 4(1) of the SFDR, in particular due to the fact that (i)no reliable and sufficiently available or accessible data are available toperform such impact measurement and provide the mandatory reporting imposed bythe regulatory technical standards in a consistent manner; (ii) the investmentstrategy and objectives of the Fund and thus its overall portfolio are neither ESG-focusednor, in the opinion of the AIFM, likely to have an impact on sustainabilityfactors and (iii) the underlying investments are not generally required to, andmay not currently, report on such factors.
Transparency of remuneration policies in relation to the integration ofsustainability risks – article 5(1)
For the purposes of article 5(1)of SFDR, the AIFM declares that it has not put in place a remuneration policyin light of the fact that it qualifies as a registered alternative investmentfund manager and thus does not fall under such requirement under the AIFMD.
Fund-relateddisclosures
Transparency of other financial products in pre-contractual disclosuresand in periodic reports – article 7 of the Taxonomy Regulation
The investments underlying this financial product do not take intoaccount the EU criteria for environmentally sustainable economic activities.