Marktlink Investment Partners B.V. (“MIP”) makes the following disclosures in accordance with articles 3(1), 4 (1) (b) and 5(1) of the Disclosure Regulation.
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 MIP, sustainability risks are risks which, if they were to crystallise, would cause a material negative impact on the value of the portfolios of its alternative investment funds (AIFs). Before any investment decisions are made on behalf of a fund that MIP manages, an investment decision process is followed. Part of the investment decisions process is that MIP aims to assess the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are taken into account by MIP when making investment decisions where needed.
MIP pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff takes into account compliance with all policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process.
Principal Adverse Impact reporting
In accordance with article 4 sub 1 (b) of the Disclosure Regulation, MIP 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 Disclosure Regulation. Given the small size of the organisation of MIP, such disclosure as set forth in article 4 sub 1 (a) of the Disclosure Regulation and the administrative burden in connection therewith would not be proportional.