In order to comply with the sustainable finance disclosure regulation Regulation (EU) 2019/2088 (SFDR), Nimbus (Nimbus Control B.V. or Nimbus Capital Management B.V. as Fund Manager) makes the following disclosures.
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 an investment decision is made on behalf of a fund that Nimbus manages, an investment decision process is followed.
Part of the investment decision process is that the risk management function of the Manager assesses the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are taken into account by the board of Nimbus when making investment decisions.
In addition, Nimbus pays staff a combination of fixed remuneration and variable remuneration (including a possible bonus). Variable remuneration for relevant staff is mainly related to divestments and also takes into account compliance with all policies and procedures which are in effect within Nimbus, 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 and are required to execute an adherence form acknowledging that they will comply with the policies.
In accordance with article 4 sub 1 (b) of the SFDR, Nimbus 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 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 Nimbus, 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. Nimbus does not manage funds which fall under article 8 or 9 SFDR, and therefore does not make the disclosures set forth in article 10 SFDR.