Regulatory Disclosure

The Financial Disclosure Regulation:

​

Sustainability risk policies:
A sustainability risk means in ESG regulations (an environmental, social or governance) event or condition that, if it occurs could cause an actual or potential material negative impact on the value of the investment. At Komy Capital LLC, sustainability risks are risks that can affect our Funds in case of occurrence.

​

Before any investment decisions are made on behalf of a Firm-managed fund, material risks associated with the proposed investment are identified and sustainability risks and considerations are integrated in investment due diligence. These risks and considerations are part of the due diligence we perform before starting any project. Following this assessment, investment decisions are made having regard to the relevant fund's investment policy and objectives, taking into consideration relevant sustainability risks and considerations and Komy Capital LLC wider policies and procedures on responsible investing.

​

Principal Adverse Impacts:
The Firm does not currently consider the adverse impacts of investment decisions on sustainability factors in the manner specifically defined by the Disclosure Regulation. While Komy Capital LLC believes that long-term value is enhanced by considering sustainability risks (as defined in the Disclosure Regulation) when investing and actively improving the Environmental, Social and Governance (ESG) practices of its investee companies, Komy Capital LLC is mindful that the detailed underlying rules in this area merit a thorough evaluation. This evaluation process is currently underway, and the position will be kept under review as the underlying rules are finalized due to the changing nature of these rules and regulations.

​

Remuneration policy:
Komy Capital LLC pays its staff a combination of fixed remuneration and variable remuneration. Variable remuneration for specific staff takes into account the compliance with all of our company policies and procedures, including those relating to risk management and the integration of sustainability risks.