Sustainable Finance Disclosure Regulation – Art. 3
Middlegame Ventures partners with the next generation of financial services innovators to help solve inclusion and technological gaps. Middlegame Ventures formally integrates an assessment of sustainability risks in its due diligence decision-making approach and restricts itself from investing in certain sectors bearing compliance or sustainability risks.
Sustainable Finance Disclosure Regulation – Art. 4
In general, sustainability risks could adversely impact Middlegame Ventures distributed funds and related investments. Currently, alignment with Article 4 of the SFDR regulation is difficult due to the overall interpretation of the set principal adverse impact rules, maturity level of ESG available data and KPI and diverse ESG source of information. Therefore, Middlegame Ventures does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFDR Regulation. Middlegame Ventures frequently collects relevant ESG related information (on a best effort basis) and shares it with its Limited Partners. The Company will pursue this approach until clarification of the regulation landscape in the Finance industry.
Sustainable Finance Disclosure Regulation – Art. 5
Middlegame Ventures risk management framework supports the investment decision-making process and ensures that excessive risk is not encouraged. Middlegame Ventures remuneration policy incentivises managers to promote sustainable growth within investments. Our management fee model is based on capital commitments and is capped (as laid out in the Limited Partnership Agreement).