Annual Statement on Principal Adverse Impacts of Investment Decisions on Sustainability
3 Comma Capital does not comply with the requirements set out in paragraphs 3 and 4 of Article 4 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 ("SFDR").
However, 3 Comma Capital maintains a proactive commitment to sustainability and the principles of Environmental, Social, and Corporate Governance (“ESG”), as outlined in its Sustainability Policy. The firm diligently assesses and manages ESG risks throughout its investment management process, including portfolio management.
Nonetheless, 3 Comma Capital does not consider the adverse impacts of investment decisions on sustainability factors as described by the Delegated Regulation (EU) 2022/1288 of 6 April 2022 (“SFDR Model” - Annex I).
Regarding principal adverse impacts on sustainability, the Delegated Regulation sets out key indicators that should be considered in identifying these adverse impacts, including greenhouse gas emissions (GHG emissions, carbon footprint, GHG intensity of investee companies), biodiversity (activities negatively affecting biodiversity-sensitive areas), water, social issues (violations of the principles of the United Nations Global Compact and the Guidelines of the Organization for Economic Co-operation and Development), gender pay gap, gender diversity, among others.
Given the type of companies - early-stage startups, pre-seed, or seed - targeted by the financial instruments managed by 3 Comma Capital, it is currently not possible to ensure the collection of all necessary elements for reporting according to the SFDR and the SFDR Model to achieve an appropriate and sufficiently comprehensive measurement of the actual adverse impacts of its investment decisions on sustainability factors.
The main challenges preventing the collection of the detailed information described in the SFDR Model are as follows:
- Publicly available information is still limited, lacking precision, accuracy, and comparability;
- Early-stage/startup companies are not required, and do not have the reasonable capacity, to provide structured ESG information as required by the SFDR Model;
- External data providers face similar difficulties in obtaining comprehensive data, and the associated costs are considered disproportionately high.
Furthermore, the current management mandates of 3 Comma Capital do not require the consideration of principal adverse impacts when making an investment decision. As a result, investors/participants in the funds do not expect adverse impacts to be considered in the Management Company's investment decisions.
Nevertheless, 3 Comma Capital commits to conducting an annual assessment of the key challenges mentioned in this regard and will adjust its approach as necessary based on evolving circumstances.
Whenever conditions are met, 3 Comma Capital intends to comply with the relevant requirements by developing processes to collect information on the sustainability impact of portfolio companies and conducting a comprehensive assessment of the principal adverse impacts.
Lisbon, June 6th, 2024
