Aglaia Management B.V. | Draft SFDR website disclosures
In order to comply with the sustainable finance disclosure regulation (SFDR), Aglaia Management B.V. (Aglaia) makes the following disclosures.
Integration of sustainability risks
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"
Aglaia views ESG as a standard topic in the pre-investment process. Before any investment decisions are made on behalf of any alternative investment fund (AIF) that Aglaia manages, an investment decision process is followed which in regard to specific investments includes the assessment of potential sustainability risks attached to a potential investment opportunity, alongside other relevant factors such as the relevant AIF’s investment policy and objectives. . Any such risks identified are considered by Aglaia when making investment decisions.
Moreover, Aglaia in connection with certain AIF’s has created – in cooperation with Sinzer (a Grant Thornton company) - the Life Sciences Impact Suite; an indicator framework enabling measurement of the socio-economic impact of Life Sciences investments. It contains 50 impact indicators in 4 different themes: Science and Innovation, Clinical, Socio-Economical, and Financial. Since 2016, Aglaia has collected data on these indicators and tested them on relevance and feasibility. The collected data are then reviewed by the (the relevant) AIF for reporting purposes. This framework creates insight in the impact performance of projects, companies and the complete AIF that uses the Life Sciences Impact Suite.
Sustainability and remuneration
In addition, - when assessing the performance of its employees - Aglaia takes into account compliance with all policies and procedures which are in effect within Aglaia, including those relating to taking into account sustainability risks on the investment decision making process.
Employees are made aware of the applicable policies and procedures when starting their employment with Aglaia.
No consideration of sustainability adverse impacts
In accordance with article 4 sub 1 (b) of the SFDR, Aglaia states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the SFDR. Given the small size of the organisation of Aglaia, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden in connection therewith would not be proportional.
 Regulation (EU) 2019/2088