Sustainable Finance Disclosure Regulation (SFDR)
Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (SFDR) is a European directive which aims at providing clarity in sustainable investments and sustainability risks disclosures to investors. It lays down sustainability disclosure obligations for fund managers toward end-investors in relation to the integration of sustainability risks in all part of the investment process. Further information is available on the European commission website.
At Astanor, all our funds are article 9 funds (with the exception of some dedicated “deal-by-deal” investment vehicles managed under the “Good Harvest Partners Management” umbrella). Our funds each have sustainability (and impact) as investment objective. You can find Astanor funds disclosures here below. For funds managed by an appointed third party manager, please refer to the website of our external AIFM.
SFDR Disclosures
All investment entities affiliated to the Astanor universe, including the Fund Manager, abide by the Astanor Responsible Investment Framework which can be consulted in the link below. The purpose of this Responsible Investment Framework is to illustrate the guiding principles which help Astanor achieve its sustainable investment objectives and impact KPIs. It encompasses consideration of sustainability factors across organizations, from the implication of implementing purposeful ESG and scaling impact standards with investees. This document forms Astanor core ESG and impact management system and helps assess, adapt, and manage the ESG and impact performance as an investor and as a firm.
Objectives
This statement aims at communicating appropriate internal structure and defining the internal responsibilities and instructions for the reception and the handling of Complaints in relation to Astanor funds, in order to ensure that they are handled in a manner which is fair, objective and truth oriented.
Protocol
Any complaint concerning an entity of the Astanor group must be sent using the complaints filing form(in appendix to the Group Complaints Handling Policy as shared below)to either compliance@astanor.com or to the following address: Astanor Ventures, c/o Compliance Department, 480 Avenue Louise 1050 Brussels – Belgium.
An acknowledgement letter or email will be sent to you within ten (10) business days as of the receipt of the complaint if the complaint cannot be settled before this timeline. An update letter or email will be sent to you one month and every four weeks thereafter to inform you of the progress of your complaint. A final letter will be sent to you to inform you on the outcome of our investigation and the actions taken to resolve the complaint.
Escalation
Where a complainant did not receive a response within one (1) month of a complaint being submitted to Astanor, the Complainant can refer its complaint to the local relevant financial authorities where the Fund operates.
Further information can be found on the Complaints Handling Policy of Astanor.
Astanor personal data fair processing policy (the “Privacy Policy”) is maintained by Astanor GP S.àr.l. and is applicable to all the Astanor Entities (as defined in the List of Astanor Entities, as amended from time to time and available upon request) (collectively, “Astanor” “Astanor Ventures”, “we”, “us” or “our”). Each Astanor Entity must formally approve abidance with this Privacy Policy and provide minutes of the Privacy Policy ratification to the compliance department of Astanor (the “Compliance Department”). The below Privacy Policy explains how Astanor collects, stores, shares, protects, and uses personal information of our website visitors, business contacts, investment advisors, investors and management teams involved in business relationship or a potential business relationship with Astanor (“you”, “your”). For the avoidance of doubt, this Privacy Policy applies to all processing of personal data, whether automated or not (including paper files) implemented by Astanor in the context of its activities.
Each partner, consultant, or employee of Astanor (an “Astanor Associate”) is responsible in case of collection of personal data necessary for the performance of their tasks and must do so in accordance with applicable internal policies (including storing personal data in appropriate folders, application or database).