Sustainable Risk Finance Disclosure Regulation (2019/2088) (the Disclosure Regulation)

Firm level website SFDR disclosure

Startup Wise Guys group (“SWG” as well as “we” and “us and its entities”) including but not limited to Wise Guys Ventures OÜ and the funds it is managing, make the following disclosures in accordance with Articles 3(1), 4 (1) (b) and 5(1) of the Disclosure Regulation.

Principal Adverse Impact Statement

In accordance with Article 4 sub 1 (b) of the Disclosure Regulation, SWG does not currently consider the principal adverse impacts of its investment decisions on sustainability factors as set out under the European Union Sustainable Finance Disclosure Regulation 2019/2088 (“SFDR”). Given the small size of the organization of SWG, such disclosure and the administrative burden in connection therewith would not be proportional. PAI statement on product level will be published in 2023, as required by the SFDR.

Sustainability risk policies

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”. For SWG, sustainability risks are risks which, if they were to crystallize, would cause a material negative impact on the value of the portfolios of its alternative investment funds. The Investment committee of SWG makes investment decisions having regard to the relevant fund’s investment policy and objectives.

Remuneration policy

SWG aims to promote sound and effective risk management, and to discourage risk-taking which is inconsistent with SWG risk profile and to avoid conflicts of interest. The integration of sustainability risks is currently not considered with respect to the determination of remuneration.

Disclaimer: It should be noted that no universally accepted framework (legal, regulatory, or otherwise) currently exists, nor is there a market consensus in terms of what constitutes a ‘sustainable’, ‘responsible’, ‘traditional’, or equivalent ‘ESG’ investment, product, or offering. Furthermore, no assurance can be given that such a universally accepted framework or consensus will develop over time. Although there have been regulatory efforts in certain jurisdictions and regions (in particular, in the European Economic Area) to define such concepts, the legal and regulatory framework governing sustainable finance is still under development. Accordingly, no assurance can be given to investors that an investment, product, or offering will meet any or all investor expectations regarding ‘ESG’, ‘sustainable’, ‘responsible’, or other equivalently labeled objectives or that no adverse environmental, social, and/or other impacts will occur.

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