Sustainability Related Disclosures

Ramphastos Investments Management B.V. (the “Fund Manager”) is a financial market participant as defined in the Sustainable Financial Disclosure Regulation (EU) 2019/2088 (the “SFDR“) amended by Regulation (EU) 2020/852 (the “Taxonomy Regulation“) as in force since March 10, 2021.

The Fund Manager manages funds that do not actively promote sustainability nor do the funds have sustainable investments as their main objective.


  • A sustainable investment is defined as an investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators on the use of energy, renewable energy, raw materials, water and land, on the production of waste, and greenhouse gas emissions, or on its 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 tackling inequality or that fosters social cohesion, social integration and labor relations, or an investment in human capital or economically or socially disadvantaged communities, provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance.
  • Promoting sustainability” means a fund promotes among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments of the fund are made, follow good governance practices.
  • 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.
  • Sustainability factors” mean environmental or social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. This is what is or can be impacted by investment decisions.

Sustainability risk policies and the integration of sustainability risks – article 3(1) SFDR

The Fund Manager does not integrate sustainability risks in its investment decision-making process. The reasons for non-integration are:

No consideration of adverse impacts of investment decisions on sustainability factors – article 4(1)(b) SFDR

SFDR requires fund managers like the Fund Manager to provide a clear statement as to whether or not they consider the “principal adverse impacts” of investment decisions on sustainability factors.

In case such fund manager does not consider principal adverse impacts, SFDR requires it to include clear reasons for why they do not do so, including, where relevant, information as to whether or when they intend to consider such adverse impacts.

The Fund Manager does not consider the adverse impacts of its investment decisions on sustainability factors at its own level nor in respect of investments of the Funds in the manner prescribed by SFDR due to:

The Fund Manager does not intend to consider principal adverse impacts of investment decisions on sustainability factors in the near future.

No remuneration policy available – article 5(1) SFDR

The Fund Manager does not have a remuneration policy in place because it qualifies as a registered alternative investment fund manager within the meaning of article 3(2)(b) of Directive 2011/61/EU of 8 June 2011 on alternative investment fund managers (the “AIFMD”) and thus does not fall under such requirement under the AIFMD. As a result, sustainability risk integration is not a performance indicator for the compensation of employees.