Website Disclosures

Sangha CVP as General Partner does not actively take investment decisions based on sustainability risks and does not actively consider the adverse impacts of sustainability risks on the returns of the Limited Partners for Sangha Capital Fund. Yet, Sangha CVP does not invest or invests limitedly in certain sectors or companies whose products, services or activities could be considered contrary to the current trends regarding the promotion of ESG criteria.

The strategy of Sangha Capital Fund to invest in venture capital is one of the contributing factors as to why sustainability risks cannot currently be actively considered. Sangha Capital Fund does not promote environmental or social characteristics, nor does it have sustainable investment as its objective. Sangha Capital Fund is therefore considered an “Article 6” financial product in accordance with the Regulation (EU) 2019/2088 of the European Parliament and the European Council of 27 November 2019 on sustainability related disclosures in the financial services sector.

Sangha CVP does not undertake an assessment of the Principal Adverse Impacts (“PAIs”) arising from its investment decisions/recommendations that have a negative effect on ESG Factors. PAIs are those impacts arising from a particular decision taken by Sangha CVP that will eventually have a negative effect on ESG Factors.

Sangha CVP intends to consider the principal adverse impacts of investment decisions on sustainability factors once the regulatory technical standards which set out the content, methodology and information required in the principal adverse sustainability impact (PASI) statement, come into effect. The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Sangha CVP will actively engage with the alternative investment funds under its
management/investors to understand whether they have any concerns about specific activities and / or industries in order to maintain such exclusions on an on-going basis.
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In such cases, Sangha CVP undertakes, to the extent possible, to screen target entities and / or products that promote and provide solutions that are consistent with ESG Factors and shall aim at recommending and / or investing in such on an on-going basis, in so far as applicable.

Sangha CVP will not knowingly invest in companies involved in the following activities: arms manufacturing, manufacture of tobacco, hard spirits, narcotics/drugs, prostitution, human traffic, gambling and genetically modified organisms. Sangha CVP will assess these types of investments on a case-by-case basis and any potential for indirect exposure is carefully considered and factored into investment selection.

Whilst Sangha CVP does not currently have any employees, no variable remuneration is paid to individual personnel providing services to Sangha CVP, unless it is determined to be justified following a performance assessment based on quantitative (financial) as well as qualitative (non-financial) criteria.
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Due to this very limited impact on the risk-profile of the alternative investment funds under Sangha
CVP’s management, as well as the nature of our business, we deem that there is no risk of misalignment with the integration of the sustainability risks, if any, in our investment decision making process.
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As such, we believe that our existing structures are sufficient to prevent excessive risk taking in respect of sustainability risks, if any.

Please contact finance@sangha.co for a full copy of our ESG Policy.