ESG Disclosures in accordance with SFDR
Pitchdrive NV (“Pitchdrive”, “we”, “us”), registered with the Crossroads Bank of Enterprises under company number 0703.977.104, having its registered office at Kleine Pieterpotstraat 8, 2000 Antwerp, is a manager of several alternative investment funds and a head office of Pitchdrive affiliated companies. Pitchdrive determines and applies group policies for all group entities referred hereafter jointly as “Pitchdrive Company” or individually as “Company.”
At Pitchdrive, we are aware of our responsibilities towards society, including those relating to environmental, social and governance (“ESG”) matters as set forth in:
- Regulation (EU) no. 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”)
- Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying the details of the content and presentation of the information in relation to the principle of “do no significant harm”, specifying the content, methodologies and presentation of information in relation to sustainability indicators and adverse sustainability impacts, and the content and presentation of the information in relation to the promotion of environmental or social characteristics and sustainable investment objectives in precontractual documents, on websites and in periodic reports (“RTS”); and
- Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (“TR”).
No environmental or social characteristics are evaluated or promoted by Pitchdrive in its investment policy in accordance with SFDR. Although Pitchdrive does not have sustainable investments as its purpose in terms of article 9 of the SFDR, we believe that sustainability factors should not be overlooked when making good investment decisions.
Pitchdrive reserves the right to modify its policy at any time. If any policy amendments occur, Pitchdrive will provide a clarification on this website.
1. Sustainability risk policies
1.1 No integration of sustainability risks
As Pitchdrive neither (i) promotes environmental or social characteristics, (ii) nor has sustainable investments as its purpose, we do not formally integrate an assessment of sustainability risks in our decision making process in accordance with article 3 of the SFDR and we do not plan to do so in the future.
We acknowledge that ESG-related events or conditions could potentially have an (unquantified) impact on the value of our investments. The transition to a low-carbon, more sustainable, resource-efficient and circular economy will affect all operators of the economy including the portfolio entities that we invest in. Nonetheless, due to Pitchdrive’s group limited size and resources, we are currently unable to formally incorporate sustainability risks into our investment decisions or conduct formal assessments of the potential impacts of sustainability risks on the returns.
1.2 Sustainability risk management
That being said, we do carefully select potential portfolio entities for investments, as well as the sectors that they are active in. In addition, through the long-term investments that the Pitchdrive funds take in portfolio entities, we may influence such portfolio entities’ activities and policies and thereby diminishing (sustainability) risks for our investments. As set out in the documentation governing our funds, no investments will be made in entities active in certain ‘restricted sectors’ (which, among others, are sectors that may entail sustainability risks).
Prior to making any investment, we conduct a thorough due diligence research on target companies. Such due diligence research, among others, focuses on the target’s compliance with applicable legislation, among which also ESG-related legislation. The outcome of the due diligence findings and assessment of the target’s compliance with (ESG) legislation is taken into consideration when an investment decision is taken by us.
1.3 Monitoring of sustainability risks
As an active investor, we seek representation on the governance bodies of our portfolio companies. Throughout the lifespan of our investments, we monitor portfolio entities’ compliance with (ESG) legislation and human rights. In addition, with their investments, our funds aim to create additional employment opportunities.
2. No consideration of sustainability adverse impacts
We are aware that our investment decisions, as well as our portfolio companies’ activities may have an impact on sustainability factors. However, for the purpose of article 4, §1, (b) and article 7, §2 of the SFDR, Pitchdrive does not consider the adverse impacts of our investment decisions on sustainability factors.
Pitchdrive does not consider those adverse impacts because we are a small organization with limited resources and personnel and we are not capable of determining precisely what the adverse impacts of our investment decisions would be based on the different criteria set forth in the SFDR and the legislation implementing the SFDR. In addition, we invest in start-ups that, due to their size and limited resources, are not capable of providing the information required for that purpose.
Pitchdrive does not intend to consider adverse impacts of investment decisions on sustainability factors in the future in accordance with article 4, §1, (b) of the SFDR for the aforementioned reasons.
3. Integration of sustainability risks into remuneration policy
As a sub-threshold manager of alternative investment funds, we do not have an obligation to have a formal remuneration policy in accordance with article 40 and following of the Belgian law of 19 April 2014 on alternative entities for collective investments and their managers. Consequently, sustainability risks are not integrated in our remuneration policy.
Last revision: May 2023.
