In order to comply with the sustainable finance disclosure regulation (SFDR) according to Regulation (EU) 2019/2088, BlueMill Management B.V. (BlueMill) makes the following disclosures.
Integration of sustainability risks. A sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment. Before any investment decision is made on behalf of a fund managed by BlueMill, a comprehensive due diligence analysis is conducted and the Investment Committee reviews the investment proposal. As part of this process BlueMill identifies all risks, including sustainability risks, assesses the likelihood of these risks materialising and estimates the impact on the value of the investment.
In addition, BlueMill pays staff a combination of fixed and variable remuneration. Variable remuneration for relevant staff takes into account compliance with all policies and procedures in effect within BlueMill, including those relating to sustainability risks in the investment decision making process. Employees are made aware of the applicable policies and procedures when starting their employment.
No consideration of sustainability adverse impacts. In accordance with article 4 sub 1 (b) of the SFDR, BlueMill states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the SFDR, because BlueMill could not reasonably gather and/or measure all relevant data of its portfolio companies at reasonable cost, and because such disclosure would not be proportional given the size of the organisation. BlueMill continues to monitor market and regulatory developments and reviews at least annually whether and when to comply with article 4 sub 1 (a) of the SFDR.
