DevCo Partners Oy (“DevCo”) is committed to sound environmental, social and governance (“ESG”) principles that are embedded into DevCo’s operations. Sustainability factors and risks are considered, among other factors and risks, in the investment process and due diligence as well as in DevCo’s ownership strategy.
DevCo has implemented a formal Responsible Investment Policy which is based on the United Nations backed Principles for Responsible Investment (“PRI”). In investment decisions DevCo follows its Responsible Investment Policy and its Sustainability Risk Policies. All DevCo’s ESG related policies and documents are reviewed at least once a year by DevCo’s Compliance Officer and Board of Directors.
2. INTEGRATION OF SUSTAINABILITY RISKS IN DEVCO’S INVESTMENT DECISION‐MAKING PROCESS
EU Regulation 2019/2088 on sustainability‐related disclosures in the financial services sector (”SFDR”) defines sustainability risk as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. DevCo, as a registered alternative investment fund manager (“AIFM”), is committed to adhering to the SFDR. In accordance with SFDR, DevCo has integrated sustainability risk assessment in every phase of its investment decision-making process and provides its investors information about sustainability risks.
Sustainability risks are considered throughout the investment life cycle, for example in the initial screening phase, as part of the due diligence evaluation and during DevCo’s ownership.
2.1 Initial screening of investment opportunities
DevCo considers sustainability risks in the initial screening phase by utilizing exclusion lists and on the other hand considering positive ESG performance. DevCo does not invest in industries that it considers to have especially high sustainability risks (such as tobacco and weapons industries).
2.2 Due diligence
After the initial screening, DevCo always undertakes extensive and tailored investment due diligence when evaluating potential investments. As an important element of this assessment, DevCo conducts a comprehensive ESG due diligence. As a result, sustainability risks are identified, evaluated and considered as one element in DevCo’s due diligence approach. DevCo aims at identifying, evaluating and considering sustainability risks that i) are relevant at the outset and ii) may become relevant due to changes in environmental or social conditions, law or policy, new information or research and other developments.
The significance of sustainability risks to the investment opportunity is always considered in the context of the industry and company in question, and the overall risk and return profile of the investment opportunity.
2.3 Ownership and reporting
DevCo is an active owner and incorporates ESG factors into ownership policies and practices. DevCo makes sure that an appropriate ESG policy is established in each of its companies. Based on this approach, sustainability risks are assessed and managed in each of DevCo’s portfolio companies throughout the ownership phase. In line with DevCo’s Responsible Investment Policy, Board of Directors, CEO and Management Team of each portfolio company have an important role in ESG matters, including assessment and management of sustainability risks.
DevCo’s ESG integration tools include analyzing ESG maturity, setting ESG KPI’s and taking into account UN SDGs.
3. ALIGNMENT OF THE REMUNERATION POLICY WITH RESPECT TO INTEGRATION OF SUSTAINABILITY RISKS
The remuneration policies of DevCo include a broad range of factors that are considered to determine the appropriate level of remuneration for individuals. In general, DevCo’s remuneration policies aim at promoting sound and effective management of all risks, including sustainability risks. Sustainability risks are not considered as a discrete and separate performance component but rather form part of the broader assessment of the relevant individual’s contribution to DevCo. Individuals at DevCo may receive performance related variable remuneration. In case of such variable remuneration, the total amount of variable remuneration shall be based on a combination of the assessment of the performance of the individual, overall performance of DevCo and its companies, as well as conduct of the employee under the internal policies, values, procedures and requirements applicable to DevCo.
4. CURRENTLY NO CONSIDERATION OF SUSTAINABILITY ADVERSE IMPACTS
DevCo does not currently consider principal adverse impacts of investment decisions on sustainability factors in accordance with Article 4 of SFDR, as the technical reporting standards, methodology and presentation of such impacts are still to be finalized. DevCo finds ESG factors and risks highly important and monitors closely the regulatory developments with respect to SFDR. During the year 2022, when the regulatory framework is expected to be finalized and clarified, DevCo will reconsider its position to take the adverse impacts into account.