Star Capital, in compliance with the provisions of UE Regulation 2019/2088 of the European Parliament and of the Council of 27 November 2019 (the "SFDR Regulation") on sustainability reporting for the financial services industry, provides the following disclosure in accordance with Articles 3.1 and 4.1.b of the Regulation.
Sustainability risk is defined as "an environmental, social or governance event or condition that, if it occurs, could cause a significant actual or potential adverse impact on the value of the investment." Sustainability risks are risks that, if they were to occur, would cause a significant negative impact on the value of the portfolio of the Funds managed by Star Capital. The company, with reference to the Regulations, has adopted its own ESG policy to integrate sustainability risks into its investment decision-making processes. Sustainability risks are considered both during the due diligence phase of a potential investment and during the monitoring of the investee portfolio companies.
The term "principal adverse impacts" refers to "the effects of investment decisions that have a negative impact on sustainability factors". Star Capital, to date, does not take into account the negative impacts as referred in the Regulatory Technical Standard (RTS) published by ESMA on February 2, 2021, because, at the time of entry in force of the Regulation, the Funds were already established and the fundraising already completed. Moreover, while waiting for further details to be defined by the competent Authorities regarding sustainability indicators, Star Capital uses, for the purpose of monitoring activities related to ESG issues, some indicators inspired by the RTS. Star Capital will be responsible for monitoring the evolution of the regulations in order to adapt its procedures to the best practice in the sector.
Milan, March 11th, 2021
Star Capital manages four Alternative Investment Funds (AIFs) classified in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 (“SFDR Regulation”).
Star Bridge Social Responsible Fund, Star III Private Equity Fund, and Star IV Private Equity Fund are classified under Article 6 of the SFDR Regulation; Star V Private Equity Fund is classified under Article 8 of the SFDR Regulation.
Sustainability risk refers to "an environmental, social, or governance event or condition which, if it occurs, could cause a material actual or potential negative impact on the value of the investment." Sustainability risks are risks that, if they materialize, could have a significant negative impact on the value of the Funds' portfolios. Therefore, Star Capital integrates ESG factors, including climate-related aspects, into the various stages of the investment process.
The integration of these aspects is governed by dedicated ESG policies (with reference to Star IV and Star V). The selection process includes a preliminary assessment of the investment opportunity, taking into account the exclusion criteria established in the AIF regulations, aimed at verifying the existence of the minimum conditions – Including the ESG profile – necessary to determine the AIF's interest in the opportunity. If such interest is confirmed, due diligence activities are carried out, including ESG due diligence. Once the transaction is finalized, the portfolio company is subject to ongoing monitoring during the investment period, including ESG aspects, which are reported for each AIF in its respective annual ESG Report, made available to Subscribers.
With reference to Star V Private Equity Fund, classified under Article 8 of the SFDR Regulation, ESG activities take into account the higher level of depth required by the SFDR. For more details, please refer to the Fund’s ESG policy available in the dedicated documents section.
Principal adverse impacts (“PAIs”) refer to “the effects of investment decisions that result in negative impacts on sustainability factors.” Although Star Capital integrates ESG risks into its investment strategy, it does not currently fully implement a policy for considering the principal adverse impacts (PAIs) of investment decisions on sustainability factors. Indeed, with particular regard to the only AIF classified under Article 8 of the SFDR Regulation, the management company assesses the PAIs of investment decisions.
With reference to the only AIF classified under Article 8 of the SFDR Regulation, please refer to the document available in the dedicated documents section, which outlines the approach adopted by Star Capital to comply with the provisions of Article 10 of the SFDR Regulation.
Star V Private Equity Fund – Policy ESG
Star V Private Equity Fund – Disclosure ex Art. 3 e Art. 4
Star V Private Equity Fund – Disclosure ex Art. 10