SFDR (latest update: August 2025)

On March 10, 2021, the European Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088, SFDR, became applicable. The SFDR emerged from the European Union’s 2018 Action Plan on Sustainable Finance and is therefore part of broader efforts at European level to make the financial sector more sustainable. The SFDR requires fund managers such as Summit Strive B.V. (hereafter “Summit Strive”) to provide information regarding (among other things) the integration of sustainability risks, the consideration of adverse sustainability impacts and, where applicable, the promotion of environmental or social characteristics, and sustainable investment as an investment objective.

Furthermore, the EU Taxonomy Regulation (EU 2018/0178, Taxonomy Regulation, as amended, restated or supplemented from time to time) is about introducing harmonized criteria to determine whether an economic activity is environmentally sustainable within the meaning of the Taxonomy Regulation.

In accordance with the SFDR, Summit Strive makes the following disclosures:

Integration of sustainability risks in the investment decision making (article 6(1)(a) SFDR)

Pursuant to the SFDR, sustainability risk means: “an environmental, social or governance event or condition which, if it occurs, could have an actual or potential material adverse effect on the value of the investment”.
In respect of the alternative investment funds managed by Summit Strive, it is noted that the investment strategy and objectives do not take into account sustainability aspects and these do not play a specific role.
In respect of the alternative investment funds managed by Summit Strive, it is noted that the investment strategy and objectives do not take into account sustainability aspects and these do not play a specific role. Integration of sustainability risks in investment decision making.

The investment funds that Summit Strive manages do not promote sustainability features (i.e. environmental or social characteristics) and do not have sustainable investments as their objective, as referred to in Articles 8 or 9 of the SFDR respectively. Due to our investment focus, it is in general not anticipated that we come across severe or material climate- or social-related risks.

To mitigate potential sustainability risk further, the following process is applied.
Before an investment decision is made on behalf of a fund that Summit Strive manages, an investment decision process is followed. Part of the investment decisions process is that Summit Strive assesses the risks attached to a potential investment opportunity during the due diligence phase, which includes sustainability risks. Identified sustainability risks are taken into account by the investment committee of Summit Strive which includes the key persons of Summit Strive, and the board of Summit Strive when making investment decisions. If the investment is made, any identified sustainability risks are subsequently discussed with the management teams of the various portfolio companies from time to time, to ensure that risks are addressed and as such mitigated and/or management as much as possible.

Principal adverse impact (PAI) statement (article 4(1)(b) SFDR)

In accordance with article 4 sub 1 (b) of the SFDR, Summit Strive states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the SFDR and therefore does not make the disclosures as described in article 4 sub 1 (a) of the SFDR.
This is mainly based on the following reasons:

• The investment strategy of Summit Strive’s current (and future) funds under management do not promote environmental or social characteristics (article 8 SFDR) and do not have sustainable investments as their objective (article 9 SFDR). As such, assessing the principal adverse impact of Summit Strive’s investment decisions is of limited value to its investors;
• In view of the experience and small size of Summit Strive’s organisation, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden and associated costs in connection therewith would not be proportional;

The above may be reconsidered on a periodic basis or under certain circumstances, for example when (i) Summit Strive’s investment policy of its current or future fund(s) under management is amended, (ii) drawing up a PAI Statement becomes considerably less onerous and burdensome than currently the case or (iii) if the majority of the investors in Summit Strive’s funds require or request such PAI Statement.

Renumeration policy (article 5(1) SFDR)

Employees play a crucial role in achieving the Summit Strive objectives and therefore form a central part of the organization. Summit Strive attaches great importance to the development of the competences of its workforce.

Remuneration depends on the job profile, experience and personal development. This is determined according to the Summit Strive salary model. Summit Strive regularly benchmarks its salary to ensure that our remuneration policy remains in line with the market and that the balance between the fixed and variable component of remuneration shall be reasonable and not encourage excessive risk taking. The manner in which employees of Summit Strive account for the management of sustainability risks is taken into account in Summit Strive’s decision to award its employees with a remuneration.

During the performance review of the partners and employees of Summit Strive, compliance with the HR handbook applicable within Summit Strive is taken into account, which includes the integration of sustainability risks in respect of investments.

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