Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)
1. Sustainability risks (Article 3 SFDR)
Clementine Capital Management GmbH (“Clementine Capital”
LEI: 391200ZLJ3J2V94T0W40) considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material negative impact on the value of the investment.
As part of Clementine Capital's standard procedure, sustainability risks are considered as part of its due diligence process prior to any investment and also include an assessment of sustainability risks. The results of such assessment are taken into account when the investment decision is being taken. Clementine Capital remains free in its decision to refrain from investing or to invest despite sustainability risks, in which case Clementine Capital may apply appropriate measures to reduce or mitigate any sustainability risks.
2. No consideration of adverse impacts of investment decisions on sustainability factors (Article 4 SFDR)
Although Clementine Capital falls below the regulatory threshold for mandatory PAI consideration under Article 4 of the SFDR. Feasibility of PAI consideration has been assessed. As the entity-level PAI regime applies on a whole-of-firm basis, any voluntary opt-in would extend to all funds under management. At present, Clementine Capital considers that the information provided by its portfolio companies across all managed funds is not sufficiently robust to enable reporting and consideration of principal adverse impacts on a firm-wide basis in accordance with the SFDR requirements.
As Clementine Capital is strongly committed to responsible investing and transparency, this position is reviewed on an ongoing basis. Nevertheless, Clementine Capital does not expect that data availability across its managed portfolios will materially improve in the near term to support voluntary opt-in. In the meantime, Clementine Capital reserves the right to make use of selected sustainability indicators listed in Annex I of the RTS and/or to apply its own set of indicators where appropriate.
3. Remuneration disclosures (Article 5 SFDR)
As a registered alternative investment fund manager within the meaning of section 2 (4) of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”), Clementine Capital does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB.
© 2025. Clementine Capital Management GmbH
Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)
1. Sustainability risks (Article 3 SFDR)
Clementine Capital Management GmbH (“Clementine Capital”
LEI: 391200ZLJ3J2V94T0W40) considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material negative impact on the value of the investment.
As part of Clementine Capital's standard procedure, sustainability risks are considered as part of its due diligence process prior to any investment and also include an assessment of sustainability risks. The results of such assessment are taken into account when the investment decision is being taken. Clementine Capital remains free in its decision to refrain from investing or to invest despite sustainability risks, in which case Clementine Capital may apply appropriate measures to reduce or mitigate any sustainability risks.
2. No consideration of adverse impacts of investment decisions on sustainability factors (Article 4 SFDR)
Although Clementine Capital falls below the regulatory threshold for mandatory PAI consideration under Article 4 of the SFDR. Feasibility of PAI consideration has been assessed. As the entity-level PAI regime applies on a whole-of-firm basis, any voluntary opt-in would extend to all funds under management. At present, Clementine Capital considers that the information provided by its portfolio companies across all managed funds is not sufficiently robust to enable reporting and consideration of principal adverse impacts on a firm-wide basis in accordance with the SFDR requirements.
As Clementine Capital is strongly committed to responsible investing and transparency, this position is reviewed on an ongoing basis. Nevertheless, Clementine Capital does not expect that data availability across its managed portfolios will materially improve in the near term to support voluntary opt-in. In the meantime, Clementine Capital reserves the right to make use of selected sustainability indicators listed in Annex I of the RTS and/or to apply its own set of indicators where appropriate.
3. Remuneration disclosures (Article 5 SFDR)
As a registered alternative investment fund manager within the meaning of section 2 (4) of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”), Clementine Capital does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB.
© 2025. Clementine Capital Management GmbH