SUSTAINABLE FINANCE DISCLOSURE REGULATION
Compliance with EU Sustainable Finance Disclosure Regulation (2019/2088) (“SFDR”)
Rise Point Capital GP S.à r.l. (“RPC” or “we”) make the following disclosures in accordance with Articles 3(1), 4(1) b) and 5 of the SFDR.
Article 3(1) – Transparency of sustainability risk policies
RPC’s strategy is primarily to co-invest alongside private equity sponsors as well as making direct private equity investments. As such, RPC integrates sustainability risks into its investment decision-making process by a combination of completing ESG-related due diligence on any new potential investments as well as reviewing the sustainability-related policies and procedures of the private equity sponsors that it partners with. With respect to any specific investment opportunity, a summary of material ESG due diligence findings (if any), including a description of any risks and opportunities identified, will be considered by RPC’s investment committee alongside other due diligence findings.
Where an investee company and/or co-investment partner has a material negative exposure to a sustainability risk, RPC may request that such risk is addressed or mitigated prior to making the relevant investment or, if considered appropriate, RPC may choose not to invest in the relevant company at all. Where applicable, RPC may also seek to exercise its governance rights with respect to its investments to influence the management of any relevant sustainability risks that have been identified.
Article 4(1) b) – Transparency of adverse sustainability impacts at entity level
RPC is required to publish information on whether it considers the “adverse impacts of investment decisions on sustainability factors” (the “Principal Adverse Impacts”) under the SFDR. RPC does not expressly or specifically consider the Principal Adverse Impacts of investment decisions on sustainability factors in connection with its products and services, as defined under and in accordance with the SFDR. This is because RPC is not currently in a position to obtain and/or measure all the data which SFDR would require RPC to report, or to do so systematically, consistently and at a reasonable cost.
Given that RPC is primarily an indirect investor in private equity through co-investments, there are limitations inherent to RPC’s investment strategy regarding the data it can collect. RPC’s underlying investments are not generally required to report on the relevant data in accordance with any consistent framework or frequency. As such, RPC’s focus is on engaging with co-investment partners regarding ESG (where deemed relevant and applicable), rather than directly at the asset level.
Article 5(1) – Transparency of remuneration policy with integration of sustainability risks
For the purposes of article 5(1) of the SFDR, RPC has not put in place a formal remuneration policy in light of the fact that it qualifies as a registered alternative investment fund manager and therefore does not fall under such requirement under the Alternative Investment Fund Managers Directive. However, as a general matter, RPC’s remuneration of employees aims to promote sound and effective risk management, as well as avoiding conflicts of interest. RPC does not believe its approach to remuneration encourages excessive risk-taking with respect to sustainability risks and any discretionary remuneration will take into account, among other factors, compliance with RPC’s policies and procedures.
Given that RPC is primarily an indirect investor in private equity through co-investments, there are limitations inherent to RPC’s investment strategy regarding the data it can collect. RPC’s underlying investments are not generally required to report on the relevant data in accordance with any consistent framework or frequency. As such, RPC’s focus is on engaging with co-investment partners regarding ESG (where deemed relevant and applicable), rather than directly at the asset level.