Skyfall Ventures AS: Sustainability Disclosures at Entity Level pursuant to SFDR

SFDR article 3 requires fund managers such as Skyfall to publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process. Sustainability risks are defined in the SFDR as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment.
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Skyfall integrates such risks in its investment decision-process for all its funds under management mainly by avoiding investments in sectors or business models that may be especially vulnerable to sustainability risk due to the products or services they offer, such as companies operating within fossil fuel extraction or deforestation-linked industries, or due to their behavior, such as companies with poor labor practices. For Skyfall Ventures Fund III AS ("Fund III"), Skyfall will also conduct, as part of its due diligence of a potential investment, an assessment seeking to identify and evaluate any sustainability risk specific to the target company or its industry and, where relevant, include covenants in term sheets that require the company to take specific actions for the purpose of mitigating any identified such risks.
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Similar to how Skyfall integrates other types of risks in its investment decision-process, it will for Fund III not invest in a company that in Skyfall's assessment is associated with unacceptable sustainability risk. Each such exclusion and its rationale will be documented in Skyfall’s internal systems.

SFDR article 4 requires fund managers such as Skyfall to publish and maintain on their websites information on whether they consider principal adverse impacts (PAI) of investment decisions on sustainability factors and, if they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons therefor, including, where relevant, information as to whether and when they intend to do so. Sustainability factors are environmental, social and employee matters, respect for human rights, anticorruption and anti-bribery matters, and PAI are the most significant negative impacts of investment decisions on these factors.
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Skyfall does not consider adverse impacts of investment decisions on sustainability factors. The reason for this is that Skyfall finds the administrative and financial burden on Skyfall and its funds' portfolio companies that would result from having to collect, compile, review and report on the necessary data to disclose under point (a) of article 4(1) of SFDR, is disproportionate for the potential benefits of such reporting.
Skyfall has not set a future date for when it intends to consider PAI in its investment decisions, but will regularly review its position.

SFDR article 5 requires fund managers such as Skyfall to publish on their website information on how their remuneration policies are consistent with the integration of sustainability risks.
Skyfall is not required to adopt a remuneration policy, and has not done so voluntarily. Skyfall will ensure that any future remuneration policies are consistent with Skyfall’s integration of sustainability risks as outlined above.