Cedrus Atlantica – Sociedade Capital de Risco, S.A., which operates in the market under the brand Cedrus Capital, is a venture capital company that manages venture capital funds, and therefore within the meaning of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019, an "AIFM" .
Thus, and aware of its growing relevance, Cedrus Capital attaches significant importance to the integration of sustainability risks; in its three aspects, namely, environmental, social and governance, which are commonly referred to as ESG risks.
Due to the growing importance of the proper integration of ESG risks and the need for standardisation and transparency of the criteria for analysing stakeholders in the financial market with regard to their investments, as well as in the form and nature of the information on this matter that is provided to its investors, clients and participants, Cedrus Capital has been monitoring and analyzing in depth all the regulation published on this matter, both at national, European and international level, with the focus of promoting a positive impact in ESG and, thus, add value and increase competitiveness, not only of Cedrus, as well as of the companies invested in and/or invested by the funds under its management.
In this way, and in compliance with the provisions of Regulation (EU) 2019/2088, of the European Parliament and of the Council of 27 November 2019 on the dissemination of Information related to sustainability in the financial services sector ("Sustainability Finance Disclosure Regulation", hereinafter "SFDR") and in the Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 ("Regulation Delegate"), Cedrus Capital discloses its Sustainability Policy, especially with regard to concerns the integration of ESG risks into Cedrus' activity.
Initial Publication: 10/03/2023
Update: 03/07/2024
The Sustainability Policy aims to define the general principles applied by Cedrus Capital, as a commercial company and as a company managing venture capital funds and, therefore, in the status of financial market participant, under the terms and for the purposes of the provisions in Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of information related to sustainability in the financial services sector (Sustainability Finance Disclosure Regulation, hereinafter, SFDR), taking into account the provisions of the aforementioned Regulation, as well as in Delegated Regulation (EU) 2022/1288, of 6 April 2022.
This Policy aims to define:
a) The main principles and objectives for integrating ESG risks that Cedrus Capital follows not only in its legal sphere, but also in the activity of asset management, especially in their investment decision-making.
b) The way in which Cedrus Capital tends to consider the weighting of negative impacts of its investment decisions on sustainability factors.
The preparation of this Policy was based on the size of Cedrus Capital, both by the scale and nature of the activity it pursues, given that it invests in companies and sectors that do not always have information available regarding this matter, at least in terms subicient and satisfactory or that can be obtained with costs and resources proportional to the size and activity of Cedrus Capital, both in terms of the size of the organisation, in particular, the human and technical resources, so it took into account a judgment of Proportionality.
Cedrus Capital, as a financial market player, must define the policies, processes and procedures necessary for the integration of ESG risks; namely, about investment decision- making, according to the vision, organic structure and dimension of Cedrus.
The policies, processes and procedures defined must be approved by the Board of Directors and disseminated to all interested parties. Cedrus Capital undertakes to define the objectives to be pursued within the scope of the integration of ESG risks, both in its internal structure and in the activity it pursues, as well as the roles and responsibilities to be assigned, in a logic of continuous review, and according to the structure, size and strategic objectives that will be defined at each moment.
Thus, and with a view not only to complying with the legislation in force on the subject of sustainability, but, and essentially, the desire to be an entity attentive to sustainability and that ebectively contributes to a more sustainable economy, fairer society and environmentally friendly planet, will make every ebort and means possible to:
a) Define and implement, as far as possible, procedures capable of integrating ESG risks in their investment analyses and, consequently, in its decision-making.
b) Define and implement, as far as possible, procedures aimed at requesting information related to the ESG performance of its targets, for the analysis of a given investment.
c) To raise awareness, whenever necessary and relevant, of the entities in which intends to invest in the need to integrate ESG risks.
d) Promote the periodic review of its internal policies, processes and procedures, where necessary and appropriate, so that, gradually and according to the growth of Cedrus Capital and its activity, approaches a full implementation of the Principles for Responsible Investment (PRI) approved by the United Nations.
In accordance with Article 2 (22) of the SFDR, a risk in relation to Sustainability is an event or condition of an environmental, social or governance nature whose occurrence is likely to cause a significant negative impact, real or potential, in the value of the investment. As a diligent and judicious management entity, Cedrus Capital seeks to guide its activity in accordance with ESG objectives and factors that are already reflected in the various legal diplomas to which it is subject, reflecting them in particular in the their investment decisions, as well as assessing the potential impacts of risks on sustainability in the income of the funds, to the extent that they are relevant to the activity of the funds under management, and in compliance with the policies of investment provided for in the fund management regulations. That said, Cedrus Capital guides its activity by the adoption and compliance with a set of ESG principles, objectives and factors that translate, for example, into the following:
a) Environmental sustainability: Cedrus Capital tends to implement measures leading to mitigation of climate change, prevention and control of pollution and waste, as well as being especially attentive, about the investments it makes, to the companies actively contributing to the transition to a circular economy, to the protection of biodiversity and ecosystems and for the reduction of the carbon footprint.
b) Social sustainability: Cedrus Capital complies with the rules relating to the prohibition of discrimination based on gender, race, religion or any other indicator that may lead to negative discrimination, prohibition of child labor and slavery, as well as adopts and respects human rights, health and safety at work, freedom of association and expression, promotes balance between personal and professional life, physical well-being and mental, diversity, health, the fight against inequalities and social cohesion.
c) Governance: In this context, Cedrus Capital operates with the premise of respecting the parity of shareholder rights, shareholder remuneration structure and shareholder remuneration of employees, the composition of the management body, the independence of the members and ebectiveness of the inspection body's action, compliance with social obligations and as well as scrupulous compliance with anti-money laundering laws of capital and terrorist financing, not only internally, but also promotes the respect for the same principles and objectives in the societies in which it invests.
As far as it is possible and within its reach, Cedrus Capital does all its best to eborts to understand in detail the corporate purpose, the activity to which they are truly dedicated, the means they use for this purpose, among others, of all companies in that invests, thus avoiding investing in any entity whose main activity commercial involves the promotion, production, distribution or marketing of products or Services related to:
a) activities considered illegal under laws, regulations, conventions and agreements national and/or international.
b) Corruption, money laundering and terrorist financing.
c) Pornography and prostitution.
d) Forced labor and child labor.
e) Violation of human rights.
f) Activities that threaten world peace.
g) Activities that promote negative discrimination.
Cedrus Capital acknowledges that the activity it pursues, inter alia, the management of alternative investment undertakings are often abected by the potential occurrence sustainability risks, so diligently and judiciously, but proportional to its size, nature and organic structure, it tends to integrate gradually ESG risks in their decision-making process that say directly respect the investments/divestments you make in the funds you have under his management.
Thus, it is the responsibility of the Board of Directors itself, advised by the areas of investment and monitoring, financial direction and legal and compliance direction, the responsibility for identifying, assessing and managing ESG risks, where this capable of attentively ensuring the information provided by the entities potentially investment target.
However, despite the intention of a gradual integration of ESG risks in the taking of decisions, in particular investment decisions, Cedrus Capital does not take into account the negative impacts of your investment decisions on the factors of sustainability, since it does not sell or manage funds that promote, among others, environmental or social characteristics or a combination of these characteristics, in the terms set out in Article 8 of the SFDR, or that they have set out in their policy investment as an objective to make sustainable investments, in accordance with the provided for in Article 9 of the SFDR. In addition to the above, and pursuant to paragraphs 3 and 4 of article 4 of the SFDR, Cedrus Capital is not covered by the criteria that define larger institutions (see Article 4(1)(b) of the SFDR).
Cedrus Capital will proceed, whenever necessary to the publication of a new or revision of the legislation in force on this matter, as well as the amendment of its dimension, organizational structure and the evolution and growth of entities in the which invests in the revision of this sustainability policy, in order to consider the progressive, timely and proportionate, the criteria of environmental sustainability, social and governance as a relevant factor for decision-making.