Shard 64 Management S.à r.l., a private limited liability company (société à responsabilitélimitée) incorporated and existing under the laws of the Grand Duchy of Luxembourg, having itsregistered office at 68/70, BOULEVARD DE LA PETRUSSE, L-2320 Luxembourg, Grand Duchyof Luxembourg, registered with the Luxembourg Trade and Companies Register (Registre deCommerce et des Sociétés, Luxembourg) with code B264283 (on course of AIFM registration);which manages certain alternative investment funds (the “AIFs”) registered in Luxembourg:Rodman Fund SCS, a Luxembourg special limited partnership (société en commanditespéciale), formed under the laws of the Grand Duchy of Luxembourg, having its registered officeat 68/70, BOULEVARD DE LA PETRUSSE, L-2320 Luxembourg, Grand Duchy of Luxembourg,registered with the Luxembourg Trade and Companies Register (Registre de Commerce et desSociétés, Luxembourg) with the code B267123; AND Kimchi Fund SCS, a Luxembourg speciallimited partnership (société en commandite spéciale), formed under the laws of the GrandDuchy of Luxembourg, having its registered office at 68/70, BOULEVARD DE LA PETRUSSE,L-2320 Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg Trade andCompanies Register (Registre de Commerce et des Sociétés, Luxembourg) with the codeB269155; makes the following sustainability-related disclosures pursuant to Regulation (EU)2019/2088 (“SFDR”).
While the AIFM does not actively take investment decisions based on sustainability risks orconsider the adverse impacts of sustainability risks, as part of of its due diligence andinvestment decision-making process, it does not invest or invests limitedly in certain sectors orcompanies whose products, services or activities could be considered contrary to the currenttrends regarding the promotion of sustainability criteria. Some sectors are completely excludedfrom investment on environmental, social or governance grounds.
The AIFM acknowledges the importance of incorporating sustainability principles into its coreprocesses and throughout the investment, ownership, and exit phases. However, havingconsidered the size, nature and scale of its activities, and as the primary objective of the AIF isto achieve attractive, sustainable, long-term, risk-adjusted returns by making venture capitalinvestments, the AIFM considers that it would not currently be proportionate for it to comply withthe detailed technical standards under the SFDR relating to the principal adverse impacts of itsinvestment decisions on sustainability factors. Moreover, given that the Sustainable FinanceDisclosure Regulation (EU 2019/2088) (“SFDR“) and the accompanying Regulatory TechnicalStandards (“RTS“) are new legislative acts, there is very little or no practical experience orpractice with regard to applying their respective provisions. Substantial legal uncertainties wouldremain when applying those provisions to the strategies pursued by the AIFM. Therefore, at thisstage, the AIFM does not yet take into account any principle adverse impact of its investmentdecisions on sustainability factors as specified in the SFDR. If and to the extent that theseuncertainties will be resolved and a practicable market and administrative practice will evolve inthis regard, the AIFM will reevaluate following them in due course.
As de-minimis / sub-threshold alternative investment fund manager under registration with theCommission de Surveillance du Secteur Financier (“CSSF”) in Luxembourg, in accordance withthe requirements of the CSSF, the AIFM does not have and does not need to have aremuneration guideline or policy.