We buy secondary shares in solid and profitable growth companies with a clear path to exit within the next three years. Minority stakes, limited involvement except exit advisory, tickets €100k–1M.
Kristian Jul Røsjø
Co-Founder / Managing Partner
kristian@soriacapital.com +47 481 91 232Askeladden & Co: Martin Schütt and Andreas Rokne
As an alternative investment fund manager, Soria Capital AS ("Soria") is required under Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the "SFDR"), as implemented in Norwegian law, to publish and maintain certain sustainability-related disclosures on its website.
The paragraphs below provide information required under the SFDR about Soria's policies on the integration of sustainability risks in its investment decisions, whether principal adverse impacts of Soria's investment decisions are considered and how Soria's remuneration policies are consistent with the integration of sustainability risks.
SFDR article 3 requires fund managers such as Soria to publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process. Sustainability risks are defined in the SFDR as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment.
Soria integrates sustainability risks in its ordinary assessment of risks associated with a potential investment and the ongoing monitoring of the portfolio. In practice, when reviewing a potential investment, Soria will seek to identify environmental, social or governance matters that could have a material negative impact on the value of the investment or on the ability to realise an exit within the contemplated timeframe. This may, for example, include matters relating to regulatory exposure, reputation, employment conditions, corporate governance, or business practices that may affect the company's attractiveness to a future buyer.
As a starting point, Soria does not give sustainability risk greater weight than other risks of a similar nature and significance to the value of the investment. A sustainability risk may, as any other financial risk, be decisive in determining that an investment is not made, either on its own or together with other risk factors, or it may be reflected in the entry price or the terms Soria seeks to agree.
SFDR article 4 requires fund managers such as Soria to publish and maintain on their websites information on whether they consider principal adverse impacts (PAI) of investment decisions on sustainability factors and, where they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons therefor, including, where relevant, information as to whether and when they intend to do so. Sustainability factors are environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters, and PAI are the most significant negative impacts of investment decisions on these factors.
Soria does not at this time consider adverse impacts of its investment decisions on sustainability factors.
The reason for this is that Soria expects that obtaining and processing the information necessary to make such assessments would require resources which, in Soria's view, would be more beneficially allocated to other purposes for the benefit of investors, in particular given (i) the absence of any sustainability profile in the fund it manages and (ii) Soria's limited size.
Soria keeps this assessment under review, but has not currently set a date for beginning to consider PAI.
SFDR article 5 requires fund managers such as Soria to publish on their website information on how their remuneration policies are consistent with the integration of sustainability risks.
Employees of Soria receive a fixed salary set by reference to their role, responsibilities and market levels, and Soria does not pay bonuses or other variable remuneration. Soria therefore considers that its remuneration structure does not encourage risk-taking that is inconsistent with the risk profile of the fund managed by Soria, including with respect to sustainability risks, and that it is consistent with Soria's integration of sustainability risks.
Certain employees may directly or indirectly participate in carried interest in respect of the fund managed by Soria. Carried interest depends on the realised, long-term performance of the fund as a whole. Since sustainability risks form part of Soria's ordinary risk assessment on a par with other financial risks, any sustainability risk that reduces the value of an investment will also reduce carried interest. Such participation does not, therefore, alter the assessment above.