ESG compliance
Sustainability
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on disclosure of information related to sustainable development in the financial services sector (OJ L 317, 9.12.2019 , p. 1; also hereinafter: “SFDR”, “SFDR Regulation”, “Regulation”) entered into force on 29 December 2019.
The regulation creates harmonised rules for financial market participants regarding transparency in relation to the introduction of sustainability risks into the activities of market participants and the consideration of adverse sustainability effects in their operations, as well as regarding the disclosure of sustainability-related information on financial products by financial market participants.
For the purposes of the SFDR, Elbrus Green Energy ASI sp. z o.o. (hereinafter also: “Elbrus Green Energy”) is qualified as a financial market participant.
Transparency of risk strategies for sustainable development
The SFDR Regulation, in Article 3(1), requires financial market participants to publish on their website their strategies for incorporating sustainability risks in their investment decision-making.
Under the provisions of Article 2(22) of the SFDR, sustainability risk means an environmental, social or governance situation or condition that, if it were to occur, could have, actual or potential, a material adverse effect on the value of an investment.
Elbrus Green Energy does not have a strategy for incorporating sustainability risks into its operations when making investment decisions. The above means that, at the moment, Elbrus Green Energy has not drawn up a comprehensive strategy that takes into account the environmental, ecological and social conditions that, if they occur, could affect Elbrus Green Energy’s investment decisions.
Elbrus Green Energy is consulting on the feasibility of developing a comprehensive strategy for incorporating sustainability risks into its business when making investment decisions in the future, which will involve updating this statement. When making investments in the future, Elbrus Green Energy does not exclude investments in Companies that incorporate sustainability factors (so-called ESG factors) in their operations, i.e. environmental, social responsibility and corporate governance factors.
Transparency on adverse sustainability impacts at entity level
When making investment decisions, Elbrus Green Energy ASI does not consider their adverse effects on sustainability factors (including not considering the main adverse effects of these decisions).
The above is primarily dictated by the recognition that the investment decisions taken by Elbrus Green Energy ASI, in its assessment, have a positive impact on sustainability factors and do not contribute to or are directly related to negative impacts. In addition, the nature of Elbrus Green Energy ASI’s business involves investing in equity instruments of unlisted entities that are usually in their early stages. Accordingly, Elbrus Green Energy does not currently consider the main adverse effects of investment decisions on sustainability factors.
Transparency of remuneration policy in relation to the introduction of sustainability risks into the business
Elbrus Green Energy, as an entity 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 a remuneration policy as referred to in Article 23(1) of that Directive. For the above reasons, and in the absence of a strategy on the introduction of sustainability risks into the business in the investment decision-making process, Elbrus Green Energy does not ensure that its remuneration policy is consistent with the introduction of sustainability risks into the business.