Sustainability Disclaimer

No consideration of adverse impacts of investment decisions on sustainability factors

The Company does not currently consider the adverse impacts of our investment decisions on sustainability factors as defined by Article 4 of the EU Sustainable Finance Disclosure Regulation (SFDR).

In our view, we do not currently have the means to obtain or measure all the data that would need to be reported under the SFDR or to do so systematically, consistently and at a reasonable cost across our fund's portfolio. This is partly because small and medium-sized companies are generally not required to report this data and may not currently do so. Partly it is because taking on the burden of reporting required data in line with the SFDR would have negative effects on resources available to find and research new, and monitor existing, portfolio positions. Given that Highway One Asset Management BV is not promoting environmental or social characteristics, or sustainable investment objectives, and are not mandated to incorporate consideration of sustainability risks in their investment decisions by the investment policies of the company, we currently find associated costs for reporting required data under SFDR too high.

We currently do not plan to incorporate consideration of adverse impacts of our investment decisions on sustainability factors, as defined by Article 4 of the EU Sustainable Finance Disclosure Regulation (SFDR), in our investment decisions in the future. We will continue to monitor the situation and will re-evaluate our approach whenever circumstances change related to our reasons for not considering the adverse impacts of our investment decisions on sustainability factors. As soon as we start considering adverse sustainability impacts of our investment decisions on sustainability factors, we shall disclose the relevant information to investors and on our website.

Integration of sustainability risks in the Compensation policy of the company

Highway One Asset Management BV currently falls under the AIFMD light regime. Operators under the light regime are not required to have a compensation policy. Due to the small size of the company, Highway One Asset Management BV currently does not have a compensation policy, and hence, we are not required to disclose how sustainability risks are integrated in the compensation policy.

On this link, you will find the latest version of Highway One Asset Management BV's sustainability-related disclosure.