Sustainability related disclosures
peach ventures management GmbH (“peach”) is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and the EuVECA-Regulation and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (the “SFDR”).
Art. 3 SFDR – Sustainability risk policies statement
peach addresses sustainability risks in its investment decision-making process insofar as relevant. “Sustainability risk” means 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. During the due diligence on potential investments, peach conducts a careful analysis of the investment's exposure to environmental, social, and governance risks that could impact its value. When identifying a sustainability risk during the due diligence on potential investments, peach decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk. peach regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns. peach does currently not expect sustainability risks to have a negative impact on peach fund I returns, due to the investment focus of the fund which is not particularly sensitive to sustainability risks. Nevertheless, it is not possible to completely eliminate all potential impacts of sustainability risks. In the event that sustainability risks do have an impact on the returns of the funds managed by peach, it is not possible to predict the extent of the impact as there are many factors to consider.
Art. 4 SFDR – No consideration of principal adverse impacts
peach does not consider principal adverse impacts of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. peach does not use sustainability indicators. Considering the numerous legal uncertainties currently related to the application of the provisions of the SFDR and the Regulatory Technical Standards (RTS) – in particular with respect to the consideration of adverse impacts – and the administrative burden resulting from such uncertainties, peach is not in a position to commit to such standard in light of its fiduciary duty to its funds and its investors. peach will constantly monitor and review the evolution around such regulations and standards and considers changing its position on adverse impacts once (i) a best practice has evolved among market participants, (ii) there is clear guidance by the administrations on the application of such regulations and (iii) the consequences of a commitment towards the consideration of principal adverse impacts are reasonably clear to peach.
Art. 5 – Remuneration Disclosure
As a registered alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and the EuVECA-Regulation, peach does not have and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.
Art. 10 SFDR – Sustainability-related information about financial products that promote environmental or social characteristics
peach ventures management GmbH (“peach”) is the alternative investment fund manager of peach ventures I fund GmbH & Co. KG (the “peach fund I”) within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and the EuVECA-Regulation and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (the “SFDR”).
This financial product promotes environmental or social characteristics but does not have as its objective a sustainable investment. The promoted characteristics are the consideration of ESG criteria throughout the lifecycle of each investment and the implementation of target impact goals during the due diligence and investment period. 100% of the investments will be in line with its investment strategy and investment restrictions. No reference benchmark has been designated to attain the environmental or social characteristics promoted by the financial product.
No sustainable investment objective
This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.
Environmental or social characteristics of the financial product
peach fund I takes ESG criteria into consideration throughout the lifecycle of each investment.
- peach defines ESG checkpoints to identify ESG risks. This is to ensure that these are proactively addressed and documented throughout our diligence and investment decision process.
- peach identifies potential ESG opportunities for each portfolio company to actively engage with the founding team post-acquisition.
- peach is working with Portfolio Companies to improve long-term sustainability and its social impact throughout the engagement period.
- peach encourages Portfolio Companies to establish governance structures and internal processes to set up ESG targets and to monitor key ESG performance indicators.
- peach acts as a resource for portfolio companies on ESG matters and engages to share best practices alongside operational assistance on environmental, social, and governance issues.
peach fund I aims to make an impact on the transformation of the Energy & Mobility growth markets by setting specific target impact goals during the due diligence and investment period. (See section “Methodologies for environmental or social characteristics” for more details.)
peach fund I intends to seek long-term capital appreciation through equity and quasi-equity investments in early-stage technology companies with a focus on the areas of energy and mobility, primarily in Europe, and mainly in Germany.
The strategy will be implemented during the due diligence process by a checklist of ESG impact factors and risk areas to be listed as well as a risk assessment on negative impacts by the potential portfolio companies.
During the investment cycle, peach fund I will support the formation of an ESG-compliant monitoring system and track its implementation and KPI improvement on a regular basis (at minimum once a year).
Specific target impact goals are intended to be identified by and jointly with the portfolio companies by methods like, but not limited to, the MIT D-Lab method P.ACT Target System.
Policy to assess good governance practices of the investee companies
As part of the due diligence and ongoing investment management, the investment team will review whether a potential investee company has good governance practices in place. This might include using ESG (environmental, social, and governance) criteria to evaluate companies' performance in areas such as labor practices, human rights, and corporate governance, conducting due diligence on investee companies to assess their management structures, employee relations, and tax compliance, engaging with investee companies through to encourage improvements in governance practices if necessary. The intensity of the assessment is carried out in accordance with the principle of proportionality. Where the manager sees higher risks of a non-compliance, they will intensify the audit.
Proportion of investments
peach fund I will invest fully in line with its investment strategy and investment restrictions. peach fund I will not invest a portion of its capital in any other asset class.
Monitoring of environmental or social characteristics
The investment team for peach fund I will collect ESG-data and KPIs from the portfolio companies initially and continuously to monitor whether the investment falls within the investment policies and whether the impact targets are reached (also see “investment strategy above and “Methodologies for environmental or social characteristics” below).
Methodologies for environmental or social characteristics
Specific target impact goals are being set during the due diligence and investment period. peach fund I will act with the intention to identify, create and track target areas and goals to help reduce an adverse impact on the environment, social and governance, e.g., sustain resources such as, but not limited to, reduction of greenhouse gas emissions, waste as well as a companies’ social and legal / governance responsibility to improve ESG relevant targets set by the respective portfolio companies in the context and ability of the respective business model.
Specific target impact goals are intended to be identified by and jointly with the portfolio companies by methods like, but not limited to, the MIT D-Lab method P.ACT Target System in which a step-by-step approach is identifying relevant impact goals, prioritization of such measures and defining the impact value chain.
Due to the early stage of investment and the novelty of some ideas, it will not always be possible to measure impact. This may be, for example, due to a lack of relevant data or suitable KPIs. In such cases, the peach reserves the right to invest even without a measurable impact, so as not to deny itself investing in promising ideas.
Data sources and processing
peach fund I receives data provided by the portfolio companies as part of the due diligence process and at regular intervals after the investment. Where necessary or beneficial, peach fund I also makes use of publicly available data. Data processing is exclusively internal and DSGVO compliant. Estimates of data are not made.
Limitations to methodologies and data
peach is partly reliant on the information provided by portfolio companies during the due diligence process. Moreover, in the post-investment phase, peach is reliant on the company’s reported data. In both cases, complete data may not always be available due to the nature of the investments. The information is verified only if and to the extent misrepresentations are suspected.
Since peach fund I’s investments are made for a multi-year investment period, peach places a high priority on establishing a trusting working relationship with the portfolio companies to ensure that data is submitted reliably and completely and that the above restrictions are met.
peach considers the promoted ESG aspects when sourcing new portfolio companies for peach fund I and during the due diligence on targeted portfolio companies. The due diligence is performed by obtaining all information relevant to peach fund I using a due diligence questionnaire, which is then reviewed internally. If necessary, further specific information is also obtained from the potential portfolio companies, should this still be necessary after the detailed questioning. The due diligence process is not externally monitored.
peach fund I invests in the portfolio companies for a period of several years. Therefore, peach makes it a priority to establish and maintain a trusting working relationship with the portfolio companies in order to continuously comply with the investment restrictions. peach thus also intends
Last Version: 04.12.2023