MANDATORY DISCLOSURES UNDER REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ON SUSTAINABLE-RELATED DISCLOSURES IN THE FINANCIAL SERVICES SECTOR (EU) 2019/2088 (“SFDR”)
I POLICIES ON THE INTEGRATION OF SUSTAINABILITY RISK IN INVESTMENT DECISION-MAKING PROCESSES
Trind Ventures OÜ (hereafter “Trind Ventures”) considers environmental, social and corporate
governance (hereafter “ESG”) criteria in their investment decision-making process insofar as they are
relevant to the technology sector. This is done by following our ESG policy which outlines our steps for
decision-making as well as sustainability monitoring.
Potential sustainability risks which could have an effect on the value of the investment are identified and
assessed prior to the investment as part of a systematic due diligence process which is grounded in ESG
assessment (hereafter “ESG DD”) where the potential investee companies are asked to fill out a
pre-determined questionnaire on relevant ESG topics.
In case of investment, the sustainability risk areas identified in the course of ESG DD are brought to the
attention of the investee and are addressed together with Trind Ventures. We advise our portfolio
companies on potential ESG improvement possibilities and encourage them to develop their own
policies to ensure proper business practices from an ESG perspective. All of the portfolio companies
commit to align themselves with Trind Venture ́s ESG principles and their sustainability advancements
will be monitored and reported annually.
In case of further interest into our ESG policy, feel free to contact us!
II NO CONSIDERATION OF ADVERSE SUSTAINABILITY IMPACTS
While Trind Ventures acknowledges potential negative externalities of the investments, it does not
formally consider adverse impacts of investment decisions on sustainability in relation to SFDR ((EU)
2019/2088) article 4.
This is due to two main reasons: a) the portfolio companies belong mostly to the tech sector where
adverse impacts on sustainability factors are rarely present, and b) due to the early development phase
of the portfolio companies, the available information is not yet sufficient to account for these impacts.
Any adverse sustainability impacts that should occur during the investment period will be evaluated by
Trind Ventures and necessary steps will be taken to address and potentially reduce or eliminate the
To date, no adverse impacts on sustainability have been identified.
III MANDATORY DISCLOSURES OF REMUNERATION POLICIES IN RELATION TO THE INTEGRATION OF SUSTAINABILITY RISKS
Trind Ventures does not apply a remuneration policy in relation to the integration of sustainability risks.
IV ENGAGEMENT POLICY
Should Trind Ventures detect any ESG issues or adverse sustainability impacts in its investments, it will
engage the portfolio company ́s board/manager to discuss potential steps for resolving, reducing or
mitigating the arisen negative effects in accordance with article 3 (g) of Directive 2007/36/EC of the
European Parliament and of the Council.