We strive to maintain high ethical standards and systematically incorporate Environmental, Social and Governance (ESG) considerations into our investment decisions, both during the initial due diligence and throughout the life of an investment. Our team conducts regular, in-depth reviews of our systems and processes, which we are convinced, improves the outcomes for our clients and investors.
Our Environmental, Social and Governance (ESG) Policy is consistent with our obligations under the Regulation (EU) 2019/2088 , our investment mandates, investment beliefs, investment strategy and international best practice.
The European Union has introduced a series of legal measures (the primary one being Regulation (EU) 2019/2088) requiring fund managers that manage investment funds including AIFs to provide transparency on whether and how they integrate sustainability considerations into their investment process with respect to the investment funds they manage.
For the purposes of disclosure under Regulation (EU) 2019/2088 we do not specifically consider adverse impacts of our investment decisions on sustainability factors and sustainability risks are not deemed relevant for our investment decisions and policies for the following reasons:
We manage an alternative equity and quasi-equity investment fund within the meaning of Directive 2011/61/EU, 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 is established following a competitive public procurement process awarded by the Fund Manager of Financial Instruments in Bulgaria EAD (“FMFIB”) as contracting authority. The fund has already been closed with its capital already been fully committed by its investors.
The integration of sustainability risks and the consideration of adverse sustainability impacts in the investment process is not among the priorities of OPIC for the programming period 2014-2020. On that basis, no ESG criteria were included in the requirements of the public procurement bid. Our investments should comply 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, we as its fund manager are not specifically required nor aim to integrate the risks of sustainability within the meaning of Art. 2 (22) of Regulation (EU) 2019/2088 in our investment decisions concerning the Fund in relation to the programme period 2014-2020 of OPIC and to consider the effects of these investment decisions on sustainability factors.
The integration of sustainability risks in our investment strategy will require the approval of our investors, both FMFIB as contracting authority as well as the private investors in the Fund. We are currently working on a proposal to be addressed to our investors for integration of sustainability risks in our investment strategy.
Although we do not prioritize integration of sustainability risks in our investment processes we strictly adhere and comply with internationally recognised responsible business conduct codes and standards for due diligence and reporting and systematically incorporate ESG considerations into our investment decisions, both during the initial due diligence and throughout the life of an investment.