In order to comply with the sustainable finance disclosure regulation (SFDR), Graduate Entrepreneur 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 decisions are made on behalf of a fund that Graduate Entrepreneur manages, an investment decision process is followed which in regard to specific investments includes the approval of the Investment Committee of such fund. Graduate Entrepreneur views ESG as a standard topic in the pre-investment process. Part of the investment decisions process is that Graduate Entrepreneur assesses the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are considered by Graduate Entrepreneur when making investment decisions.
In addition, Graduate Entrepreneur pays staff a combination of fixed remuneration and variable remuneration (including a possible bonus). Variable remuneration for relevant staff also takes into account compliance with all policies and procedures which are in effect within Graduate Entrepreneur, including those relating to taking into account sustainability risks on the investment decision making process.
Employees are made aware of the applicable policies and procedures when starting their employment with Graduate Entrepreneur.
No consideration of sustainability adverse impacts
In accordance with article 4 sub 1 (b) of the SFDR, Graduate 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 Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the SFDR. Given the small size of the organisation of Graduate Entrepreneur, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden in connection therewith would not be proportional.
 Regulation (EU) 2019/2088