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The Sustainable Finance Disclosure Regulation
As of 10 March 2020, the European Regulation on sustainability-related disclosures in the financial sector (also known as the SFDR) came into force. As a result, SFDR managers of investment funds like Cyber Capital need to be transparent in how they integrate sustainability risks in their investment decision process. Sustainability risks concern environmental as well as social issues, like respect for human rights and prevention of corruption and bribery.
Below you will find information on how Cyber Capital applies the SFDR and what this means for the investment fund(s) managed by Cyber Capital.
Although Cyber Capital supports a more sustainable society, our funds do not specifically target sustainability or social aspects in any way. We, therefore, do not offer a fund that promotes environmental or social characteristics in its investments (“ light green” in accordance with article 8 SFDR), nor do we offer a fund that has sustainable investments as objective (“dark green” in accordance with article 9 SFDR).
Integration of sustainability risks in the investment process
A sustainability risk is a risk that an environmental, social, or governance event that, if it occurs, could cause a significant negative impact on the value of an investment. As such events, you can think of climate change or human rights controversies. These can have an impact on the value of certain investments. Given the type of investments of our fund(s), crypto assets, we generally do not take sustainability risks into account as these are, in our view, not of significant importance for Cyber Captial. However, in our due diligence, we take into account anti-money laundering and sanction aspects into account.
Principal adverse impact on sustainability
Cyber Capital does not consider principal adverse impact of investment decisions on sustainability factors. The reason for this is:
- The principal adverse indicators included in the SFDR, which can be observed, are focused on investments in investee companies, real estate and sovereign bonds and, therefore, not tailored to crypto assets.
- Besides, to a certain extent, the energy consumption involved in the production of crypto assets, there are, as we currently see, no relevant aspects to consider regarding the adverse impact on sustainability. Reliable data on energy consumption of different crypto assets is not available or only to be obtained for relatively high costs. Energy consumption is also not a material element for our investment decisions.
- If Cyber Capital decides to take into account the principal adverse impact on sustainability factors, it would then have to comply with several detailed requirements on reporting, of which a large part is not relevant for our investments.
For these reasons, Cyber Capital is not anticipating taking the principal adverse impact of investment decisions into account in the future.