Newion Partners B.V. (hereafter referred to as “Newion”) is obligated to adhere to the European Sustainable Financial Disclosure Regulation ((EU)2019/2088) (referred to as “SFDR”). As per SFDR requirements, Newion is responsible for publishing its policy on integrating sustainability aspects into its investment practices and reporting on the sustainability impact of its funds.
Integration of sustainability risks
Newion incorporates sustainability risks into its investment decision-making process. These risks encompass environmental, social, or governance events or conditions that have the potential to negatively affect the value of investments. Newion assesses the risks associated with potential investment opportunities, including sustainability risks, as part of its decision-making process.
Sustainability risks may vary from investment to investment and could include risks of environmental damage, social risks (including safety and human rights violations and exploitation), governance risks (inadequate oversight and internal governance of the companies, board structure, compensation and approach to anti-bribery and anti-corruption), litigation risks linked to ESG issues, as well as the risk of political and regulatory changes on investments related to each of the foregoing.
Newion has a structured investment approach to mitigate such risks and ensures that investments are aligned with Newion’s investment strategy. When selecting investments, Newion considers sustainability risks across asset classes, sectors, and geographies on the basis of length and maturity. Newion ensures that during the investment due diligence, potential sustainability risks are identified. Once identified and evaluated as financially material for an individual investment, sustainability risks and the mitigation thereof are directly integrated in the related investment decision.
Newion has identified the most important and relevant sustainability risks for the Newion funds and included the likely impact of the sustainability risks, if they occur, on the returns of the investments.
Newion maintains the freedom to decide whether to invest or abstain from investing, even when sustainability risks are present. In cases where investments are made despite the existence of sustainability risks, Newion may implement measures to mitigate or reduce these risks. Throughout this process, Newion adheres to the principle of proportionality, considering the strategic relevance of the investment and its transactional context.
We aim to implement fair remuneration principles which are structured in such a way that promotes effective risk management, discourages excessive risk-taking, and avoids potential conflicts of interest.
No consideration of adverse impacts of investment decisions on sustainability factors
In line with Article 4, Subsection 1(b) of SFDR, Newion explicitly declares that it does not consider adverse impacts of investment decisions on sustainability factors as outlined in Article 4, Subsection 1(a) of the Disclosure Regulation. Consequently, Newion does not disclose information as described in Article 4, Subsection 1(a) of SFDR. Given the small size of the organization of Newion, such disclosure and the administrative burden in connection therewith would not be proportional.
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