Sustainability
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on disclosure of information related to sustainable development in the financial services sector (OJ L 317, 9.12.2019, p. 1; also referred to as: "SFDR", "SFDR Regulation", "Regulation") entered into force on 29 December 2019.
This act establishes harmonised rules for financial market participants and financial advisers regarding transparency with regard to the introduction of sustainability risks into their activities and the consideration of adverse sustainability impacts in their operations, as well as with regard to their presentation of sustainability-related information on financial products.
On the basis of the SFDR Regulation, Nunatak Capital sp. z o.o. (hereinafter also: "Nunatak Capital") is qualified as a financial market participant and the alternative investment company it manages, Nunatak Capital spółka z ograniczoną odpowiedzialnością ASI S.K.A. (hereinafter also: "ASI") - constitutes a financial product.
Transparency of risk strategies for sustainable development
The SFDR Regulation in Article 3(1) requires financial market participants to publish on their website their strategies for introducing sustainability risks into their business when making investment decisions.
According to the provisions of Article 2(22) of the SFDR, sustainability risks mean environmental, social or governance situations or conditions that, if they occur, could have, actual or potential, a material adverse effect on the value of an investment.
Nunatak Capital does not have a strategy for incorporating sustainability risks in its investment decision-making process.
Nunatak Capital does not exclude the possibility of developing a strategy for incorporating sustainability risks into its business in its investment decision-making process in the future, which will involve updating this statement.
Transparency on adverse sustainability impacts at the entity level
Due to the character of its business, which involves investing in equity instruments of unlisted entities, Nunatak Capital does not currently consider the main adverse effects of investment decisions on sustainability factors.
Nunatak Capital, as an entity referred to in Article 3(2) of Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers and amending Directives 2003/41/EC and 2009/65/EC and Regulations (EC) No 1060/2009 and (EU) No 1095/2010, is not required to adopt a remuneration policy as referred to in Article 23(1) of that Directive. For the above reasons, and in the absence of a strategy on the introduction of sustainability risks into the business in the investment decision-making process, Nunatak Capital does not ensure that its remuneration policy is consistent with the introduction of sustainability risks into the business.