Sustainable Risk Finance Disclosure Regulation (2019/2088) (the Disclosure Regulation)

Rockstart Enterprises B.V., Rockstart Ventures Management B.V. and its affiliates (Rockstart) makes the following disclosures in accordance with articles 3(1), 4 (1) (b) and 5(1) of the Disclosure Regulation.

Sustainability risk policies

A sustainability risk means “an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment”. For Rockstart, sustainability risks are risks which, if they were to crystallize, would cause a material negative impact on the value of the portfolios of its alternative investment funds (AIFs).   

Before any investment decisions are made on behalf of an AIF, Rockstart performs due diligence which covers inter alia sustainability risks. The investment committee of Rockstart aims to assess the identified risks (including sustainability risks) alongside other relevant factors set out in an investment proposal. Following its assessment, the investment committee of Rockstart makes investment decisions having regard to the relevant AIF’s investment policy and objectives.

Rockstart intends to implement the principles of the UN Global Compact and UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises and ILO’s conventions on fundamental principles and rights at work in the operation of the AIFs it manages.

Remuneration policy

Rockstart pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff takes into account compliance with all policies and procedures, which will include those relating to the impact of sustainability risks on the investment decision making process in future.

Principal Adverse Impact reporting

In accordance with article 4 sub 1 (b) of the Disclosure Regulation, Rockstart states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the Disclosure Regulation. Given the small size of the organization of Rockstart, such disclosure and the administrative burden in connection therewith would not be proportional.