Information under Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on disclosure of information related to sustainable development in the financial services sector (“SFDR Regulation”).
Under the Regulation, SFDR Vinci S.A. is qualified as a financial market participant, while the alternative investment companies managed by the Company: HiTech ASI S.K.A., IQ ASI S.K.A. and Da Gama ASI S.K.A. (“ASI”) – constitute financial products.
Vinci S.A. ‘s financial products do not promote environmental or social aspects or those aimed at sustainable investments.
When implementing investments, ASI managed by Vinci S.A. finance enterprises that, among others, take into account factors conducive to sustainable development. This is one of the investment criteria that can be taken into account when making an investment decision.
Vinci S.A. is aware of the risks associated with climate change and the environment in the process of making investment decisions. In the investment process, Vinci S.A. also takes into account the criteria related to them, within the scope of: (i) supporting entities implementing investments in the field of high-tech industries or allowing to contribute to the improvement of the natural environment, and (ii) enabling the modernization of industries that will be most exposed to changes in the climate policy of the European Union.
Strategy regarding the introduction of risks to sustainable development in the process of making investment decisions in accordance with art. 3 of the SFDR Regulation
Vinci S.A. does not have a strategy for introducing risks to sustainable development in the process of making investment decisions. However, Vinci S.A. does not exclude the possibility of developing such a strategy in the future.
Transparency in terms of adverse effects on sustainable development in accordance with art. 4 of the SFDR Regulation.
When making investment decisions, no adverse effects on sustainable development factors are considered, taking into account the nature of the business related to investing in capital instruments of unlisted entities. This is due to the lack of publication by these entities of relevant or sufficient information necessary to analyze the adverse effects of investment decisions on sustainable development.
Vinci S.A. does not exclude taking into account in the future the main adverse effects of investment decisions on sustainable development factors in the management of ASI.
Consistency of remuneration policy with the introduction of risks to sustainable development into operations in accordance with art. 5 of the SFDR Regulation.
The policy of variable remuneration components of Vinci S.A. (“Remuneration Policy”) has been developed taking into account the provisions of Article 5 sec. 1 of the SFDR Regulation, which imposes the obligation to include in remuneration policies information on how to ensure the consistency of these policies with the introduction of risks to sustainable development into operations. Ensuring the consistency of the Remuneration Policy with the introduction of risks to sustainable development into operations is carried out by including in the assessment under qualitative criteria, which is the basis for granting variable remuneration, compliance with generally applicable law and internal regulations, including within the scope related to ESG.
Vinci S.A. assesses whether the employees to whom the Remuneration Policy applies counteract the promotion of behaviors aimed at exposing Vinci S.A. or ASI managed by it to excessive exposure in relation to risks to sustainable development and supports actions encouraging compliance with generally applicable law and internal regulations, including those related to ESG.