Legal
Disclosures Pursuant to Regulation (EU) 2019/2088
The following information is published by
Earlybird GmbH & Co. KG, LEI: 529900OPVG0POG9FIY70,
Earlybird DWES Management GmbH & Co. KG, LEI: 391200WTLBHSLUAQ7E17,
Earlybird Growth Management GmbH & Co. KG, LEI: 391200ORMRHHLXBPG420,
Earlybird VC Management GmbH & Co. KG, LEI: 391200I4BXYVYHZO5X71, and
Earlybird Venture Capital GmbH & Co. KG, LEI: 391200H3M2LXJFE4KH85,
(each an “Earlybird ManCo” and together “Earlybird”)
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”).
Each Earlybird ManCo is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”) and/or the EuVECA-Regulation. Unless the information is explicitly provided in relation to a specific Earlybird ManCo or specific fund managed by any of the Earlybird ManCos the following statements refer to the management and investment decision-making processes of all Earlybird ManCos in general.
Article 3 SFDR – Sustainability Risk Policies Statement
Earlybird addresses sustainability risks in its investment decision-making process. ‘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. A standardized sustainability risk questionnaire that is mandatory to be completed as part of the due diligence process prior to an investment decision ensures the adequate and systematic assessment of the main sustainability risk factors associated with a proposed investment. Identified “red flags” need to be brought to the investment committee’s attention and without cure or adequate mitigation an investment will not be pursued.
Earlybird regularly reviews its sustainable risk policies to ensure that they address new and emerging risks as well as investors’ concerns.
Article 4 SFDR – No Consideration of Principal Adverse Impacts
Earlybird does not consider principal adverse impacts (“PAI”) of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social, and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters.
The standardized catalog of PAI indicators (“PAII”) provided by Annex I of the regulatory technical standards issued under the SFDR is not tailored to the specific needs of Earlybirds venture capital investment strategy.
In the vast majority of 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 Earlybird. Therefore, collecting data on PAII will not only increase the administrative burden and costs but also fail to provide a new perspective for Earlybird.
Earlybird is open to considering PAI in the future if it becomes evident that doing so would significantly enhance the ability of Earlybird to identify and mitigate possible adverse impacts of the investments while maintaining operational efficiency and cost-effectiveness.
Article 5 SFDR – Remuneration Disclosure
Earlybird GmbH & Co. KG
The remuneration of managing directors and staff with control functions of Earlybird GmbH & Co. KG is governed by an internal remuneration policy that complies with the requirements of Section 37 of the German Investment Code (KAGB) in conjunction with Article 13 and Annex II of Directive 2011/61/EU. In addition to fixed remuneration, variable remuneration components may also be granted. When assessing whether variable remuneration is to be paid, non-financial criteria may also be taken into account. Compliance with internal policies, including the Responsible Investment Policy, may be taken into account positively in the assessment. Conversely, breaches of such policies may lead to a reduction in variable remuneration. However, specific ESG targets whose achievement would be a prerequisite for the payment of variable remuneration are not defined.
Remaining Earlybird ManCos
The other Earlybird ManCos, as registered alternative investment fund manager within the meaning of the KAGB and/or the EuVECA-Regulation, do not have and do 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.
Sustainability-Related Disclosures
