1. Risks related with Sustainability
Alpac Capital – Sociedade de Capital de Risco, S.A. is a venture capital company and is therefore covered by Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of information related to sustainability in the financial services sector (the "SFDR Regulation") established a set of harmonised transparency rules for the services sector financial, including the obligation for financial market participants to publish and update on their websites a set of sustainability-related information in their investment decision-making processes.
Alpac Capital – Sociedade de Capital de Risco, S.A. it is not covered by the criteria 3 and 4 of Article 4 of the SFDR Regulation which define the largest institutions.
According to the SFDR Regulation, "sustainability factors" are considered "environmental, social and labour issues, respect for human rights, the fight against corruption and bribery", "sustainability risks" are an event or conditions of an environmental, social or governance nature whose occurrence is likely to cause an actual or potential significant negative impact on the value of the investment, and "sustainable investments" investments in an economic activity that contributes to an environmental objective, as measured, for example, by key indicators of resource efficiency in terms of energy use, renewable energy, raw materials, water and soil, waste generation and greenhouse gas emissions, either the impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to combating inequalities or that promotes social cohesion, social integration and industrial relations, or an investment in human capital or in economically or socially disadvantaged communities, provided that such investments do not significantly undermine any of those objectives and provided that the undertakings benefiting from the investment employ good governance practices, in particular with regard to sound management structures, industrial relations and remuneration practices for staff and compliance with tax obligations.
Alpac – Sociedade de Capital de Risco, S.A., as a diligent entity, is governed by the highest ethical values, basing its conduct on several principles, including responsible investment, recognizing that environmental and/or social risks at the level of investments made by the funds under its management may affect its activity and the profitability of these investments. Due to the importance of developing sustainable practices within the financial system and the business fabric, as well as the significant impact that the occurrence of sustainability risks may have on the value of the assets that make up the funds under its management, Alpac Capital – Sociedade de Capital de Risco, S.A. considers it on a case-by-case basis, and in compliance with the mandates assigned under the regulations governing the management of the funds it has under management, the various risks that may be relevant to the investments of the funds it manages, including in an ancillary manner sustainability risks, taking into account, to the extent that its management mandates so permit, your responsibility as a fund manager to work with the entities they are affiliated with to develop and apply appropriate and sustainability-oriented practices and principles. However, Alpac Capital – Sociedade de Capital de Risco, S.A. does not currently market or manage venture capital funds that promote, among others, environmental or social characteristics or a combination of these characteristics (provided for in Article 8 of the SFDR Regulation), nor venture capital funds that aim at sustainable investments (provided for in Article 9 of the SFDR Regulation), however, it should not be excluded that such characteristics and objectives may be achieved indirectly in compliance with the investment policies provided for in the regulations governing the management of venture capital funds managed by them.
2. Non-consideration of the negative impacts of investment decisions on sustainability factors
Without prejudice to its diligent and judicious action, Alpac – Sociedade de Capital de Risco, S.A. does not currently consider the negative impacts of investment decisions on sustainability factors, for the following reasons:
- The type of entities participating in the funds managed by it on this date does not have sufficient and/or satisfactory sustainability information, in particular on the indicators listed in Annex I to Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing the SFDR Regulation in this regard, and it is not possible to obtain such information with resources that are considered proportionate to the size of those entities subsidiaries of either Alpac – Sociedade de Capital de Risco, S.A. itself, so a reasonable consideration of the negative impacts of investment decisions on sustainability factors based on such information is not possible;
- The management mandates of Alpac – Sociedade de Capital de Risco, S.A. do not currently provide for sustainability factors to be considered for the purposes of investment decisions.
Thus, for the purposes of paragraph 1 of article 4 of the SFDR Regulation, Alpac Capital – Sociedade de Capital de Risco, S.A. does not currently have to ensure the consideration of the negative impacts of investment decisions on sustainability factors. Without prejudice to the above, and taking into account the strategic vision of Alpac – Sociedade de Capital de Risco, S.A., this is a matter that, due to its relevance, is reviewed and is periodically reassessed, taking into account, in particular, the indicators listed in Table 1 of Annex I to Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022.
3. Remuneration Policy
The current remuneration policy at Alpac considers the integration of sustainability risks, but does not make remuneration contingent solely on the achievement of positively defined sustainability objectives.
Therefore, sustainability risks are not regarded as a distinct and separate performance component. Instead, they are part of a balanced, proportional general assessment of each type of risk considered, the type of activity performed, the overall contribution of the respective employee to Alpac, and the performance of the company as a whole. This includes indicative performance criteria applicable to Alpac (which encompass the achievement of sustainability objectives), integrating also the procedures and practices adopted by the company for the identification, measurement, management, and monitoring of specific risks, including sustainability risks.
Nevertheless, Alpac defines its remuneration policies in compliance with applicable legislation, recognising that the remuneration policy is a central tool for aligning the personal goals of employees with the long-term interests of Alpac, and, through these, the managed funds and their investors. This alignment promotes the creation of permanent and sustainable employment, ensures job security, and offers dignified remuneration to all employees.
Alpac acknowledges the necessity for the remuneration policy to consider sustainable investment objectives while ensuring fair, equitable, and non-discriminatory remuneration conditions capable of attracting, retaining, and motivating employees. This includes addressing environmental, social, and governance issues, proportional to the type of activity performed, indirectly influencing remuneration practices, as they form one of the criteria used in evaluating employees' professional performance, thus ensuring team balance, efficiency, and diversity.
4. Final Considerations
With the aim of reducing information asymmetry and increasing transparency regarding the integration of sustainability risks in investment decisions, all the information published above is known to all employees and regular service providers of Alpac and has been approved by Alpac's Board of Directors.
Alpac is committed to keeping the information provided here up-to-date, reviewing it annually and adapting it in line with the evolution of applicable legislation and best market practices.
First uploaded in April 2023
Updated July 2024
Read here the Portuguese version.