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SFDR

TIN Capital disclosure statement under the SFDR and Taxonomy Regulation

In accordance with the Sustainable Finance Disclosure Regulation (the SFDR), TIIN Capital B.V. and TIN Capital Fund Management B.V. (collectively referred to as TIN Capital) provide the following statements:

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Qualification of the Fund under the SFDR

TIN Capital only complies with the disclosure requirements pursuant to Article 6 SFDR. As TIN Capital does not promote environmental and/or social characteristics (“light-green” within the meaning of Article 8 SFDR) with the Funds and the Funds do not have sustainable investments as its objective (“dark-green” within the meaning of Article 9 SFDR).

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No taxonomy alignment

The investments in the portfolio companies of the Funds do not take into account the EU criteria for environmentally sustainable economic activities. Therefore, the investments are not in economic activities that qualify as environmentally sustainable under Article 3 of the Taxonomy Regulation.

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Integration of sustainability risks in investment decision-making procedures

The SFDR defines ‘sustainability risk’ as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. TIN Capital acknowledges that sustainability risks could, if they occur, have a real or potentially substantial negative impact on the value of the investments made by the Funds. Consequently, TIN Capital considers these sustainability risks when assessing investment opportunities in potential portfolio companies.

 

Remuneration policy in relation to the integration of sustainability risks

TIN Capital applies a remuneration policy, which is consistent with, and promotes, effective risk management and does not expose TIN Capital or the Investors to excessive risk. TIN Capital’s Management and team members are required and remunerated to act in the best interest of TIN Capital, the Funds and the Investors, including compliance with TIN Capital’s policies and procedures.

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No principal adverse sustainability impact statement

Within the meaning of the SFDR, ‘sustainability factors’ means environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

Taking into account its size, the nature and scale of activities and the characteristics of the Funds and itself, currently TIN Capital does not specifically consider the potential impact of its investment decisions on sustainability factors within the meaning of the SFDR. Consequently, it does not prepare an annual “principal adverse sustainability impacts statement” (hereinafter: principal adverse impact (PAI) statement). This is mainly based on the following reasons:

  • If TIN Capital would decide to take into account the adverse sustainability impacts of investment decisions, a detailed statement would need to be prepared annually in a prescribed format, as required under the SFDR. In preparing these statements, numerous detailed requirements must be taken into account, many of which are not (or not in full) available in respect of the type of investments that are included in the portfolio of the Fund. TIN Capital only considers it appropriate to issue an impact statement on an annual basis if it were to promote sustainability factors or sustainable investments, enabling investors to assess whether the set contractual boundaries in this respect are being complied with by TIN Capital;

  • Preparing a PAI-statement would furthermore take up a large number of employees or staff to perform such assessment of the sustainability factors, who would otherwise be available to perform activities contributing to the core business of the Funds. Furthermore, performing such annual PAI statement would involve various types of costs and would be time-consuming, which – given the size of the organization – is considered to be disproportional;

  • TIN Capital does not promote environmental or social characteristics or a combination of these characteristics with the Funds, nor does TIN Capital aim for sustainable investments with the Funds. Therefore, it is considered that such PAI statement is less meaningful to measure the possible impact of investment decisions.

The above may be reconsidered under different circumstances, for example when TIN Capital’s investment policy changes, the preparation of an impact statement becomes less onerous than it currently is or appears to be, or the majority of the Investors have a need for a PAI-statement. In such case, this information will be updated accordingly.

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