No consideration of sustainability adverse impacts
This statement addresses requirements as set out in SFDR specifically relating to the consideration of principal adverse impacts of investment decisions on sustainability factors. Under the SFDR, principal adverse impacts shall be understood as those impacts of investment decisions and advice that result in negative effects on sustainability factors.
ClimbPace Capital does not consider the adverse effects of investment decisions on sustainability factors and therefore does not prepare a so-called principal adverse sustainability impact statement (PAI statement) annually. The fund managed by ClimbPace Capital does not promote ecological or social characteristics and does not have sustainable investments as its objective. Taking into account adverse effects of investment decisions on sustainability factors would bring that ClimbPace Capital must obtain necessary information to be able to report on those factors. ClimbPace Capital believes that there is currently insufficient reliable data available to determine the potential negative effects of investments in relation to sustainability. Where detailed data is available, it is often expensive to obtain and time-consuming to analyse. ClimbPace Capital believes that, also considering the nature, scale and the phase in which the ClimbPace Capital finds itself (managing one fund without promoting sustainable factors), the costs of including such effects in the investment process do not outweigh the expected benefits. At this stage, ClimbPace Capital does not consider principal adverse impacts of investment decisions on sustainability factors within the meaning of the SFDR regulation.
The foregoing does not prevent ClimbPace Capital from reconsidering the decision to not consider adverse effects of investment decisions on sustainability factors if relevant circumstances arise. For example, if the majority of investors value the consideration of adverse effects of investment decisions on sustainability factors (and thus a PAI statement). However, this is not anticipated at the time of publication of this information.
Dated 1 June 2025