Silverline Partners OOD (hereafter “Silverline” or the “Fund Manager”) is an alternative investment fund manager within the meaning of Directive 2011/61/EU established under Bulgarian Law. The only fund currently under management is Silverline Partners – Fund KD (the “Fund”), which is an alternative equity and quasi-equity investment fund, co-funded with public resources from the European Structural and Investment Funds (“ESIF”), provided under Operational Programme Innovation and Competitiveness 2014-2020 (“OPIC”) in accordance with OPIC Priority Axis 2, Investment Priority 2.2: Capacity for SMEs to grow, as well as funds provided by independent private investors. The Fund was established following a competitive public procurement process awarded by the Fund Manager of Financial Instruments in Bulgaria EAD (“FMFIB”) as contracting authority. The Fund under management has already been closed with its capital already fully committed by its investors.
The European Union has introduced a series of legal measures, most notably Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (the „SFDR“), requiring investment fund managers, including managers of alternative investment funds (“AIFs”), to provide transparency on whether and how they integrate sustainability considerations into their investment process with respect to the investment funds they manage. Importantly, SFDR adopts a disclosure-based “comply or explain” approach providing financial market participants, such as Silverline, with flexibility in addressing sustainability considerations. In that respect and pursuant to Article 4 of the SFDR, there is no substantive requirement for financial market participants such as Silverline to consider adverse impacts of their investment decisions on sustainability factors including environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters (“Adverse Sustainability Impacts” or “ASIs”). Instead, the regulation imposes a transparency obligation, where financial market participants such as Silverline are required to only disclose whether or not they consider these ASIs. Thus, where a market participant has opted not to consider such impacts, this triggers the obligation to provide reasoned explanation for why it has opted not do so.
On that basis and in compliance with article 4(1)(b) of the SFDR and article 12 of the Delegated Regulation (EU) 2022/1288, Silverline has elected to apply the “explain” approach and accordingly makes the following disclosure:
Silverline does not consider any adverse impacts of its investment decisions on sustainability factors.
This approach reflects the specific context and mandate of the Fund Manager. In particular, the integration of sustainability risks and the consideration of adverse sustainability impacts in the investment process were not among the priorities of OPIC for the programming period 2014-2020. Consequently, sustainability criteria were not included in the requirements of the public procurement bid, which instead, focused on compliance with the eligibility criteria entrenched in the financial instrument under OPIC and the applicable EU regulations governing ESIF.
In view of the specific purposes of the Fund, there was neither a specific requirement nor a strategic objective at the time to integrate the risks of sustainability within the meaning of Art. 2 (22) of SFDR in the investment decisions concerning the Fund in relation to the programme period 2014-2020 of OPIC, nor to consider the effects of these investment decisions on sustainability factors. Consequently, the Fund manager does not formally consider the adverse impacts of these legacy investment decisions on sustainability factors, as the capital was deployed in accordance with the specific regulatory and contractual obligations, and the Fund’s capital is fully committed under a mandate that predates the current SFDR framework.
The Fund Manager continuously monitors developments in ESG regulation, reporting standards, and the availability and reliability of ASI-related data. Silverline re-evaluates its position regarding the potential integration of ASIs assessment as part of its investment decisions on an annual basis. Any change to the integration of sustainability considerations would require the prior approval of the Fund’s investors, including FMFIB as contracting authority and the Fund’s private investors. Given that the Fund is closed and its capital fully committed, any future integration of ASI considerations would be expected to apply primarily to new mandates or future financial instruments, rather than to the existing investment framework.
Although Silverline does not prioritise integration of sustainability risks in its investment processes, it is committed to highest standards of business conduct and strictly adheres to and complies with internationally recognised responsible business conduct codes throughout the investment lifecycle, including during due diligence, investment decision-making, and ongoing portfolio monitoring.
Last updated on: 30.06.2025