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We see ourselves as a responsible investor and consider sustainability risks in the investment decision-making process. Our disclosures under Articles 3, 4 and 5 of Regulation (EU) 2019/2088 can be found here.

Statement on the main adverse effects of investment decisions on sustainability factors

Date of publication: 9 November 2023

Market participant: Finatem Fonds Management Verwaltungs GmbH [LEI Finatem IV GmbH & Co. KG: 529900V2UMYRH1SG2L89]



Finatem Fonds Management Verwaltungs GmbH ("Company" or "Finatem") considers principal adverse impacts of its investment decisions on sustainability factors for its fund Finatem IV GmbH & Co. KG [LEI 529900V2UMYRH1SG2L89] in accordance with the scope of application explained below. The present statement is the consolidated statement on principal adverse impacts on sustainability factors of Finatem.

This statement on principal adverse impacts on sustainability factors covers the reference period from 1 January 2022 to 31 December 2022.


Scope of application: The fund Finatem IV GmbH & Co. KG is covered by this statement. The funds Finatem II GmbH & Co. KG und Finatem III GmbH & Co. KG are not covered by this statement.


Sustainability indicators: To assess and measure the principal adverse impacts of investment decisions on sustainability factors, Finatem uses the following sustainability indicators: GHG emissions; carbon footprint; GHG intensity of investee companies; exposure to companies active in the fossil fuel sector; share of non-renewable energy consumption and production; energy consumption intensity per high impact climate sector; activities negatively affecting biodiversity-sensitive areas; emissions to water; hazardous waste and radioactive waste ratio; violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises; lack of processes and compliance mechanisms to monitor compliance with UN Global Compact principles and OECD Guidelines for Multinational Enterprises; unadjusted gender pay gap; board gender diversity; exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons); investments in companies without carbon emission reduction initiatives; breakdown of energy consumption by type of non-renewable sources of energy; rate of accidents.


Adverse impacts on the sustainability indicators used: The following statements can be made for the reference period, taking into account the available data: All five portfolio companies endeavour to keep GHG emissions as low as possible; unfortunately, only Scope 1 and Scope 2 emissions can be determined so far. Emissions other than CO2 emissions play practically no role. Other impacts on biodiversity, water and waste are also of secondary importance in the specific business models. ESG criteria were already taken into account at the investment stage. For social and employment matters, in many cases no monitoring processes have appeared necessary to date for the small structures involved.


Data: The company uses various data sources to identify and assess the aforementioned sustainability indicators. The ability to consider the principal adverse impacts depends largely on the availability of the relevant information. The required data is not available to a sufficient extent and in the required quality for all portfolio companies in which the company invests via the managed funds. If the required data is not available and cannot be obtained, the best possible alternatives are used to determine the data (e.g. estimates or projections). The company must review the data situation at least once a year, attempt to optimise it and report in the reporting format specified by the RTS.


The detailed “Description of key adverse impacts on sustainability factors” (in German) can be found here.