• SFDR Disclosures – Skaala Co-Invest GP S.à r.l. and Skaala Co-Invest I SCSp

    25.06.2025

    Skaala Co-Invest GP S.à r.l. (the AIFM), a Luxembourg-based registered alternative investment fund manager within the meaning of article 3(2)(b) of Directive 2011/61/EU of 8 June 2011 on alternative investment fund managers (AIFMD), makes the following disclosures for the purposes of Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector (SFDR) and Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (the Taxonomy Regulation).  As clarified by the European Commission in its Q&As on sustainability-related disclosures published on 14 July 2021, the AIFM must comply with certain SFDR requirements applicable to registered alternative investment fund managers.

    The AIFM acts as registered alternative investment fund manager of Skaala Co-Invest I SCSp (the Fund). 

    The Fund qualifies under article 6 of the SFDR as it integrates the sustainability risks into the investment decision-making process but it does not promote environmental or social characteristics (article 8 of the SFDR) nor does it have sustainable investments as its objective (article 9 of the SFDR).

    1. AIFM-related disclosures

    Transparency of sustainability risk policies and transparency of the integration of sustainability risks – article 3(1) 

    General overview 

    A sustainability risk refers to an environmental, social or governance (ESG) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.

    The AIFM reviews and assesses potential sustainability risks within the meaning of SFDR as part of its decision-making processes with respect to investments to be made by the Fund and has integrated such review within its internal procedures and policies, as further detailed hereafter. 

    Relevance of sustainability risks

    Sustainability risks may affect the Fund’s performance having regard to the types of investments made or to be made in accordance with its investment policy and objectives, meaning that if any such risk occurs, returns on investments may be materially negatively affected as a result. Investors and potential investors should note that it is difficult to assess with reasonable certainty the probability of the occurrence of such risks and the likely impact of such materialized sustainability risks on the value of investments.

    Assessment process 

    The identification and assessment of risks, including sustainability risks, will take place on an ongoing basis if and when investments are made in accordance with the Fund’s investment policy. Such review is performed by the AIFM, as summarized below:

    • Prior to an investment decision being taken on behalf of the Fund and the AIFM identify the material risks, including sustainability risks, associated with the proposed investment.
    • These risks form part of the overall investment proposal to be assessed by the AIFM.
    • Ultimately and following its assessment, the AIFM makes the relevant investment decision having regard to the Fund’s investment policy and objectives and subject to the Investment Committee’s approval.

    No consideration of adverse impacts of investment decisions on sustainability factors – article 4(1)(b)

    Article 4(1) of the SFDR requires fund managers such as the AIFM to provide a clear statement as to whether or not they consider the “principal adverse impacts” of investment decisions on sustainability factors, i.e. environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. 

    In case such fund manager does not consider such principal adverse impacts, article 4(1)(b) of the SFDR requires it to include clear reasons for why they do not do so, including, where relevant, information as to whether and when they intend to consider such adverse impacts.

    Although ESG and sustainability risks are important to the AIFM, the latter does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by article 4(1) of SFDR. In addition to the fact that the AIFM does not take an “active” role in managing the underlying target investments of the Fund’s target funds it manages, the AIFM considers that the relevant data needed to identify and weight principal adverse sustainability impacts is not yet available in the market to a sufficient extent or of the required quality.

    The AIFM will review the data situation on a regular basis as well as its arrangements with managers of target funds and, if necessary, decide again on this basis on the possibility of taking into account principal adverse impacts of investment decisions on sustainability factors as part of its strategy.

    Transparency of remuneration policies in relation to the integration of sustainability risks – article 5(1)

    For the purposes of article 5(1) of SFDR, the AIFM declares that it has not put in place a remuneration policy in light of the fact that it qualifies as a registered alternative investment fund manager and thus does not fall under such requirement under the AIFMD.