SFDR Disclosures
The SFDR forms part of the European Commission's action plan on sustainable finance and imposes new transparency obligations and periodic reporting requirements on financial market participants (including authorised and registered alternative investment fund managers (“AIFMs”)) at both product and entity level.
As a financial market participant, Archangel I GP S.à.r.l. (the “GP”), as general partner and registered alternative investment fund manager of Archangel I SCSp (the “Fund”) makes the following disclosure in accordance with SFDR.
The investments underlying the Fund do not take into account the EU criteria for environmentally sustainable economic activities. The Fund is a financial product falling within Article 6 SFDR.
Integration of Sustainability Risks
A sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.
Sustainability risks are considered by the GP when selecting and managing the activities and investments of the Fund. The GP's prior assessment is that the likely impact of sustainability risks on the returns of the Fund is low.
No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors
In accordance with Article 4 SFDR, the GP is required to make a “comply or explain” decision as to whether it considers the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors.
In this respect, the GP does not currently consider any adverse impacts of its investment decisions on sustainability factors. The GP lacks the necessary resources and sufficiently reliable, complete and comparable data to comply with the requirements of the PAI regime, considering the nature and size of the Fund's investments, which consist of pre-seed to Series A financing rounds in early-stage, defence-focused start-ups.
Therefore, while supportive of the policy aims of the PAI regime, the GP does not currently intend to consider such adverse impacts and has not set a specific date for doing so. This decision will be kept under review having regard to the indicators set out in Annex I to Commission Delegated Regulation (EU) 2022/1288 and to the availability and quality of the relevant data.
Remuneration
The GP's remuneration policy is consistent with its approach to the integration of sustainability risks and does not encourage excessive risk-taking that would be inconsistent with the risk profile, investment strategy or constitutional documents of the Fund.
The GP is remunerated by means of a General Partner's Share payable by the Fund, calculated by reference to the Fund's aggregate commitments during the Fund's investment period and, thereafter, by reference to the aggregate acquisition cost of the Fund's investments, as further described in the Fund's limited partnership agreement. This remuneration structure does not encourage excessive risk-taking that would be inconsistent with the sustainability risk profile of the Fund's investments.