ICEO RED GP S.à r.l., a private limited liability company (société à responsabilité limitée) incorporated and existing under the laws of the Grand Duchy of Luxembourg, having its registered office at 2, place de Strasbourg, L-2562 Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg Trade and Companies Register (Registre de Commerce et des Sociétés, Luxembourg) with code B277947 (on course of AIFM registration); which manages a certain alternative investment fund (the “AIF”) registered in Luxembourg: ICEO RED FUND I SCSp, a Luxembourg special limited partnership (société en commandite spéciale), formed under the laws of the Grand Duchy of Luxembourg, having its registered office at 2, place de Strasbourg, L-2562 Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg Trade and Companies Register (Registre de Commerce et des Sociétés, Luxembourg) with the code B278616; makes the following sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”).
Integration of Sustainability Risks (Article 3 SFDR)
While the AIFM does not actively take investment decisions based on sustainability risks or consider the adverse impacts of sustainability risks, as part of of its due diligence and investment decision-making process, it does not invest or invests limitedly in certain sectors or companies whose products, services or activities could be considered contrary to the current trends regarding the promotion of sustainability criteria. Some sectors are completely excluded from investment on environmental, social or governance grounds.
Principle adverse sustainability impact statement (Article 4 SFDR)
The AIFM acknowledges the importance of incorporating sustainability principles into its core processes and throughout the investment, ownership, and exit phases. However, having considered the size, nature and scale of its activities, and as the primary objective of the AIF is to achieve attractive, sustainable, long-term, risk-adjusted returns by making venture capital investments, the AIFM considers that it would not currently be proportionate for it to comply with the detailed technical standards under the SFDR relating to the principal adverse impacts of its investment decisions on sustainability factors. Moreover, given that the Sustainable Finance Disclosure Regulation (EU 2019/2088) (“SFDR“) and the accompanying Regulatory Technical Standards (“RTS“) are new legislative acts, there is very little or no practical experience or practice with regard to applying their respective provisions. Substantial legal uncertainties would remain when applying those provisions to the strategies pursued by the AIFM. Therefore, at this stage, the AIFM does not yet take into account any principle adverse impact of its investment decisions on sustainability factors as specified in the SFDR. If and to the extent that these uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, the AIFM will reevaluate following them in due course.
Remuneration policies (Article 5 SFDR)
As de-minimis / sub-threshold alternative investment fund manager under registration with the Commission de Surveillance du Secteur Financier (“CSSF”) in Luxembourg, in accordance with the requirements of the CSSF, the AIFM does not have and does not need to have a remuneration guideline or policy.