Sustainable Risk Finance Disclosure Regulation

Vinthera Venture Hybrid GP S.à r.l (“Vinthera”) makes the following disclosures in accordance with Articles 6(1) and 7(2) of the Sustainable Risk Finance Disclosure Regulation (EU/2019/2088) (the “SFDR”).

Vinthera is domiciled at 121, avenue de la Faïencerie, L-1511 Luxembourg, Grand Duchy or Luxembourg, and is subject to the laws of Luxembourg. Vinthera qualifies as a private limited liability company (société à responsabilité limitée) pursuant to the Law of 10 August 1915 on commercial companies and shall act as a registered alternative investment fund manager pursuant to the Law of 12 July 2013 on alternative investment fund managers.

Integration of sustainability risks

A sustainability risk means “an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment.” In the context of Vinthera, sustainability risks are risks which, if they were to crystallize, would cause a material negative impact on the value of the portfolios of Vinthera’s funds. Vinthera endeavors to identify and mitigate sustainability risks, although there can be no guarantee that Vinthera will successfully identify and mitigate all material risks.

No consideration of sustainability adverse impacts.

While Vinthera takes sustainability and ESG risks very seriously, Vinthera does not consider the principal adverse impacts of its investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFDR.

This is because Vinthera is currently not in a position to obtain and/or measure all the data which it would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost with respect to all investment decisions.

EU criteria for environmentally sustainable economic activities. 

The investments underlying these financial products do not take into account the EU criteria for environmentally sustainable economic activities

Vinthera’s stance on this matter will be reviewed periodically by reference to market developments.

Remuneration policy.

Vinthera pays staff a combination of fixed remuneration (salary) and variable remuneration (including, for example, bonus). Variable remuneration allocated to staff reflects both personal and firm performance. Compliance with Vinthera’s risk management policies and procedures and risk control measures (which relate to, among other types of risk, sustainability risks) are considered in assessing the level of an individual’s variable remuneration. The performance assessment criteria also consider quantitative measures that might, depending on the role and responsibilities of the staff member, include financial metrics which would be impacted by the crystallisation of risks.