Impact

The Footprint Fund Manager A/S

As an alternative investment fund manager, the Footprint Fund Manager (the “Manager”) is under the scope of the EU Sustainable Finance Disclosure Regulation2019/2088 (the “SFDR”) and the delegated regulations hereof, which requires the Manager to publicly disclose information on their website about their policies on integration of sustainability risk, whether and how principal adverse impacts (“PAI”) of investment advice are considered as well as how the remuneration policies are consistent with the integration of sustainability risks.

Integration of sustainability risks

Sustainability as a risks factor refers to environmental, social, or governance (“ESG”) events that, if they occur, could cause an actual or a potential material negative impact on the value of the investments.

The Manager leverages its internal capabilities as well as other capabilities by the Footprint Firm Team to identify risks and validate the sustainability contribution and commercial prospects of potential investments. The Manager integrates sustainbility risk in its investment-decision making process. As environmental, social and governance, including health, safety, and (work) environment and labour rights, (ESG) is a key priority for the Manager, The Manager will in all material respects comply with Footprint Firm’s internal policies regarding ESG, as well as applicable laws, regulations and sanctions which integrates sustainability risk in its investment-decision making process in accordance with SFDR art. 3.

It is important to take into account and mitigate such sustainability risks in order to generate sustainable long-term risk adjusted returns for investors in the AIFs under mangement of the Manager. To identify sustainability risks related to an investment, the Manager conducts an ESG due diligence which, among others, addresses potential ESG risks and the overall impact of the company’s activities, e.g., by considering portfolio companies’ resilience to regulatory changes and physical climate risk.

In general, transitional sustainability risks for the Manager is primarily related to a slow-down or lack of ESG regulation as opposed to the opposite. Tightened ESG regulation would result in a competitive advantage for the investments since all of them provide sustainable solutions. As such, an identified sustainability risk is lack of regulation and incentives for market practitioners which may in turn affect the profitability and operations of green products such as the investments.

Statement of principal adverse impacts of investment decisions on sustainability factors

In accordance with SFDR Article 4 the Manager considers Principal Adverse Impacts (“PAI”) on the sustainability factors listed in the Annex I to the SFDR Delegated Regulation 2022/1288 (“RTS”) in the investment decision-making process. These PAI indicators, comprising the 14 mandatory indicators, form an integral part of the pre-investment assessment. The Manager has identifyed the following two indicators from tabel 2 and tabel 3 in the Annex I of the delegated regulation as being relevant:

– Lack of CO2e emission reduction initiatives
– Lack of supplier code of conduct

The PAI Statement will be published on the Manager’s website annually, no later than 30 June.

Remuneration

The Footprint Fund Manager are not taking sustainability risk into consideration in their remuneration policy, as there is not direct connection between the Managers work with remuneration and the Manager’s integration of sustainbility risk in the investment-decision making process.

The Footprint Fund I K/S

Product disclosures

The financial product, The Footprint Fund I K/S (the “Fund”), has sustainable investment as its objective and discloses pursuant to Article 9 of the SFDR. The Footprint Fund I K/S is managed by The Footprint Manager.

Download our SFDR Article 9 website disclosure. about

Key information documents

Download The Footprint Fund I KID Class A about

Download The Footprint Fund I KID Class B about