Sustainable
Finance
Disclosure
Regulation

In order to comply with the sustainable finance disclosure regulation (SFDR) according to Regulation (EU) 2019/2088, BlueMill Management B.V. (BlueMill) makes the following disclosures.
 

Integration of sustainability risks

​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".   
 

Before any investment decisions are made on behalf of a fund that BlueMill manages, an investment decision process is followed which in regard to specific investments includes conducting a comprehensive due diligence analysis and having the Investment Committee of an alternative investment fund managed by BlueMill review the investment proposal and provide advice on it. As part of this investment process, BlueMill identifies all risks, including sustainability risks, associated with an investment and then assesses the likelihood of these risks materializing. It also estimates the (negative) impact that such realization could have on the value of the investment. Sustainability risks are therefore addressed and mitigated in this process.
 

In addition, BlueMill pays staff a combination of fixed remuneration and variable remuneration (including a possible bonus). Variable remuneration for relevant staff also takes into account compliance with all policies and procedures which are in effect within BlueMill, including those relating to taking into account sustainability risks in the investment decision making process.

Employees are made aware of the applicable policies and procedures when starting their employment with BlueMill.
 

No consideration of sustainability adverse impacts

In accordance with article 4 sub 1 (b) of the SFDR, BlueMill 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 SFDR.
 

At this stage BlueMill does not consider the adverse impacts of its investment decisions on sustainability factors, (i) because BlueMill could not reasonably gather and/or measure all the relevant data of the portfolio companies of BlueMill, taking into account reasonable cost for clients and investors and (ii) due to  the small size of the organisation of BlueMill, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden in connection therewith would not be proportional.

BlueMill continues to closely monitor the market developments (including the level of availability of the data) as well as the regulatory developments. BlueMill will at least on an annual basis review whether and when to comply with article 4 sub 1 (a) of the SFDR.