The SFDR requires the fund managers that are not covered by SFDR’s criteria set out in Article 4(3) and (4) of the SFDR to disclose if they consider adverse impacts of their investment decisions on sustainability factors, namely, to make a “comply or explain” decision whether to consider the principal adverse impacts (“PAIs“) of its investment decisions on sustainability factors, in accordance with a specific regime outlined in SFDR, in the Taxonomy Regulation and in the RTS (the “PAI regime”).
Bright Ventures is not covered by the above SFDR’s criteria which applies to larger institutions and, accordingly, has exercised its option not to comply with the PAI regime, both generally and in relation to the Funds under management, hereby stating that it does not take into consideration the adverse impacts of its investment decisions on sustainability factors.
Bright Ventures has thoroughly assessed the requirements of the PAI Regime and is supportive of the goals pursued by the PAI regime. However, Bright Ventures understands not to be in conditions to opt to comply with the requirements of the PAI regime, due to its size, nature and the scale of its activities and, as in particular, considering that:
(i) its investment scope is limited to sectors and geographic areas that entail limited adverse impacts on sustainability,
(ii) it invests in small entities and start-ups that, due to their size and limited resources, are not capable of providing the information required to determine precisely the adverse impacts of the investment decisions in accordance with the SFDR, the Taxonomy Regulation and the RTS,
(iii) it’s an organisation with limited resources and personnel and not capable of determining precisely what the adverse impacts of its investment decisions would be, based on the different criteria set forth in the SFDR, the Taxonomy Regulation and the RTS, and
(iv) companies and market data providers are not yet ready to make available all necessary data for the PAI regime. In practice, access to information on sustainability factors requires the use of external information sources, involving high costs that are disproportionate to the investment policy of the funds currently under management.
Currently Bright Ventures does not market or manage funds that promote, among others, environmental or social characteristics or a combination of both (as set out in Article 8 of the SFDR) nor those aimed at sustainable investments (as set forth in Article 9 of the SFDR). As such, the underlying investments of said funds do not consider the EU criteria applicable to environmentally sustainable economic activities.
Bright Ventures will keep its decision not to comply with the PAI regime under regular review but despite such current decision, Bright Ventures is aware that its investment decisions, as well as its portfolio entities’ activities may have an impact on sustainability factors and, as such, takes into account, whenever applicable, constructive ESG-related initiatives and policies, as part of Bright Ventures´ overall commitment to ESG matters, benefiting, in particular, from being part of a Corporate Group – Sonae – that highly values its commitment to ESG matters.
Last Updated on July 8th, 2024
Approved and first published on August 7th, 2023
