SFDR
Sustainability Related Disclosures
Nucleus Capital Fund Management GmbH (“Nucleus Capital”) is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) 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
Nucleus Capital 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, Nucleus Capital conducts a careful analysis of the investment's exposure to environmental, social, and governance risks that could impact its value by utilizing an ESG Assessment Questionnaire. The results of these assessments are carefully considered in investment decisions.
Furthermore, all investments undergo negative screening based on an exclusion list to comprehensively analyze their exposure to environmental, social, and governance risks.
When identifying a sustainability risk during the due diligence on potential investments, Nucleus Capital 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.
Nucleus Capital regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.
Art. 4 SFDR – Consideration of Principal Adverse Impacts
Nucleus Capital considers the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors and reports on them annually.
“Sustainability factors” mean environmental, social, and employee matters, respect for human rights, anti-corruption, and anti-bribery matters.
As part of the due diligence review, Nucleus Capital collects ESG data on each potential target company using a comprehensive ESG questionnaire. All 14 mandatory PAI indicators, one additional environmental PAI indicator (investments in companies without carbon reduction initiatives), and one additional social PAI indicator (lack of a human rights policy) are considered.
The data collected on the PAIs is then used to assess potential risks, identify areas for improvement, and discuss the findings with the respective portfolio company.
Nucleus Capital decides on a case-by-case basis on the prioritization of key negative impacts associated with or arising from the respective portfolio company’s business activities, taking into account the early stage of its portfolio companies and the sector.
If concerns arise, they will be addressed during the due diligence review or in a follow-up onboarding workshop with the portfolio company.
This contributes to the Responsible Investment Policy implemented by Nucleus Capital, which ensures the integration of the PAIs into the investment process and factors in international standards such as the UN PRI.
Given that the SFDR and the accompanying Regulatory Technical Standards ("RTS") are relatively new legislative acts, there is very little practical experience or precedent concerning the application of their respective provisions. Therefore, substantial legal uncertainties remain when applying those provisions to the strategies pursued by Nucleus Capital.
However, a best-effort approach will be undertaken for the reporting.
Art. 5 – Remuneration Disclosure
As a registered alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB), Nucleus Capital 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.
This exemption, however, does not affect our commitment to a fair and transparent remuneration policy.
Our approach to compensation is rooted in principles of equity and fairness. We ensure that pay decisions are free from bias and based on objective factors such as job responsibilities, experience, performance, and market competitiveness.
Our remuneration process is transparent, clearly communicating how pay levels and adjustments are determined, with regular benchmarks against local standards to ensure market competitiveness. Additionally, we are fully compliant with relevant wage and labor laws, including the principles of minimum wage, overtime pay, and equal pay for equal work as outlined in Article 157 of the Treaty on the Functioning of the European Union.
While sustainability risks are not currently a factor in determining remuneration, our overall policy is designed to attract and retain talent while adhering to our core values of fairness and regulatory compliance.