This statement constitutes compliance with the requirements set out in the Regulation of the European Parliament and of the Council (EU) 2019/2088 of 27 November 2019 on the disclosure of information related to sustainable development in the financial services sector (Official Journal of the European Union L 317 of 2019, page 1, as amended; hereinafter also referred to as “SFDR,” “SFDR Regulation,” or “Regulation”).
Under the SFDR Regulation, ASI management (hereinafter also referred to as “ZASI”) qualifies as a participant in the financial market, and alternative investment companies managed by them (hereinafter also referred to as “ASI”) constitute financial products.
Unless otherwise stated in this statement, when referring to ASI or an Alternative Investment Company, this should be understood as any of the alternative investment companies managed by ZASI, namely:
- Mountnut Investment Limited Liability Company Alternative Investment Company Limited Partnership;
- Mountnut Investment Limited Liability Company Real Estate Alternative Investment Company Limited Partnership;
- Mountnut Investment Limited Liability Company Mr3 Alternative Investment Company Limited Partnership.
Information on strategies for integrating sustainability risks into the investment decision-making process
The SFDR Regulation in Article 3(1) requires financial market participants to publish on their website strategies for integrating sustainability risks into the investment decision-making process.
In accordance with Article 2(22) of the SFDR, sustainability risks mean environmental, social, or governance conditions or events that, if they occur, could have a material adverse impact on the value of investments.
Subject to the implementation of remuneration policy guidelines aimed at defining remuneration arrangements to ensure that their level is in line with prudent and effective risk management, including sustainability risk management, as defined in Article 2(22) of the Regulation of the European Parliament and of the Council (EU) 2019/2088 of 27 November 2019 on the disclosure of information related to sustainable development in the financial services sector (Official Journal of the European Union L 317 of 9 December 2019, page 1), and promoting them, and not encouraging risk-taking that is not consistent with ASI’s risk profile and internal regulations, ZASI does not have a strategy for integrating sustainability risks into the investment decision-making process concerning ASI. Sustainability risks, understood as risks related to environmental, social responsibility, or corporate governance events or conditions that, if they were to occur, could have a material adverse impact on the value of investments through their interaction with other risk factors, may be indirectly taken into account when making individual investment decisions.
ZASI does not exclude the possibility of developing a strategy for integrating sustainability risks into the investment decision-making process in the future, which will be associated with the update of this statement.
When making investment decisions, adverse effects on sustainability factors are not taken into account
Given the scale of its operations and its primarily non-public market investment nature, ZASI currently does not take into account the main adverse effects of investment decisions on sustainability factors. The reason for ZASI’s decision not to consider the main adverse effects of investment decisions on sustainability factors in the course of its activities is the identified lack of data or, in some cases, significantly limited data required for analysis when declaring the consideration of the main adverse effects of investment decisions on sustainability factors, as well as the high cost associated, in particular, with the need to engage external advisors, in the event of a change in ZASI’s approach to not considering the main adverse effects of investment decisions on sustainability factors.
Information on ensuring consistency of remuneration policies with the integration of sustainability risks
ZASI, as referred to in Article 3(2) of Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on alternative investment fund managers and amending Directives 2003/41/EC and 2009/65/EC and Regulations (EC) No 1060/2009 and (EU) No 1095/2010, is not required to adopt the remuneration policy referred to in Article 13 of this Directive.
Notwithstanding the above, taking into account the position presented by the European Commission in response to the query of the Joint Committee of the European Supervisory Authorities – EBA, ESMA, and EIOPA, as well as the position of the Polish Financial Supervision Authority, ZASI has adopted guidelines on remuneration principles that apply to:
- Members of the Management Board; and, in the event of their appointment or employment:
- Members of the Supervisory Board;
- Other individuals performing tasks that have a significant impact on the risk profile of ZASI or ASI, including individuals responsible for:
a) making investment decisions;
b) implementing tasks related to the compliance system;
c) implementing tasks related to the internal audit system;
d) implementing tasks related to risk management.
- Individuals who are part of senior management;
- Other employees receiving total remuneration at the same level as senior management and the individuals mentioned above who take risks in their professional activities that have a significant impact on their risk profile.
The application of the Guidelines is excluded for individuals whose tasks include the performance of auxiliary activities, due to the significant limitation of the impact of their activities on risk.
The Guidelines define the principles of remuneration formation upon entering into a legal relationship, requiring the body deciding on the amount of remuneration for a given person to ensure that its amount is in line with prudent and effective risk management, including risk management for sustainable development, as defined in Article 2(22) of the Regulation of the European Parliament and of the Council (EU) 2019/2088 of 27 November 2019 on the disclosure of information related to sustainable development in the financial services sector (Official Journal of the European Union L 317 of 9 December 2019, page 1), and promote them, and do not encourage risk-taking that is not consistent with ASI’s risk profile and internal regulations.
Regarding the principles of determining the amounts of remuneration awarded in connection with the assessment of an individual’s achievements, the Guidelines require that, in addition to the individual’s individual results, the assessment should determine whether incidents related to risk management, including sustainability risk management, and violations of legal compliance, including those related to sustainable development in the financial services sector, have occurred during the period under review, with the individual’s involvement. In the event of the identification of events as described above, the body deciding on the award and amount of the payment is required to assess the role of the individual in the identified event.
The Guidelines apply to incentive programs if they are adopted.
The use of discriminatory criteria is prohibited when implementing the Guidelines.
