Legal
Disclosures Pursuant to Regulation (EU) 2019/2088
Article 3 SFDR – Sustainability Risk Policies Statement
Earlybird Health addresses sustainability risks in its investment decision-making process insofar as relevant. “Sustainability risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. During the due diligence process on potential investments, Earlybird Health conducts a thorough analysis of the investment's exposure to environmental, social, and governance (“ESG”) risks that could impact its value. This is supported by a mandatory, standardized sustainability risk questionnaire, which addresses ESG criteria across the value chain and ensures a systematic assessment of the key sustainability risks associated with the proposed investment. Any identified "red flags" must be brought to the attention of the investment committee, and without appropriate mitigation or resolution, the investment will not proceed. Earlybird Health regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.
Article 4 SFDR – No Consideration of Principal Adverse Impacts
Earlybird Health does not consider principal adverse impacts (“PAI”) of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social, and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters. Earlybird Health does not use sustainability indicators. The standardized catalog of PAI indicators (“PAII”) provided by Annex I of the regulatory technical standards issued under the SFDR is not tailored to the specific needs of investment strategy of Earlybird Health. In the vast majority of instances, data will be insufficient for analyzing PAI, and on occasions where data is obtainable, it tends to offer little in terms of comparability and fails to provide additional insights for Earlybird Health. Therefore, collecting data on PAII will not only increase the administrative burden and costs but also fail to provide a new perspective for Earlybird Health. Earlybird Health is open to considering PAI in the future if it becomes evident that doing so would significantly enhance the ability of Earlybird Health to identify and mitigate possible adverse impacts of the investments while maintaining operational efficiency and cost-effectiveness.
Article 5 SFDR – Remuneration Disclosure
As a registered alternative investment fund manager within the meaning of the KAGB and the EuVECA-Regulation, Earlybird Health does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration. Updated [27] January 2025 to reflect updated internal policies.
Sustainability-Related Disclosures
Please find below the SFDR policies for your download.
