Declaration

Declaration of Non-Consideration of Adverse Impacts on Sustainability Factors

In accordance with Article 12 of Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022, which supplements Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying in greater detail the content and presentation of information related to the principle of «do no significant harm» the content, methodologies, and presentation of information related to sustainability indicators and adverse sustainability impacts, and the content and presentation of information related to the promotion of environmental or social characteristics and sustainable investment objectives in pre-contractual documents, websites, and periodic reports, LINCE CAPITAL, despite applying the necessary professional diligence in assessing its investment decisions pursuant to Article 4(1)(b) of the SFDR, and intending to reflect these considerations in policies in due course, does not take into account the adverse impacts of investment decisions on sustainability factors. This position is justified by the following reasons:

– Lack of Available Information: Given the type of investments made by the funds under management, the level of publicly available information regarding ESG, particularly the indicators listed in Annex I of Commission Delegated Regulation (EU) 2022/1288, is insufficient to adequately consider the adverse sustainability impacts of investment decisions based on such information. Furthermore, the current legal landscape remains fragmented and underdeveloped in this regard, with unresolved interpretative issues, in addition to a lack of similar regulations outside the EU, rendering meaningful comparison difficult and impeding adequate consideration of adverse impacts.

LINCE CAPITAL, therefore, believes that there are not enough public information sources containing elements that are satisfactorily comprehensive, rigorous, and comparable, nor are there clear and uniform criteria required to adequately consider the adverse sustainability impacts of its investment decisions.

– Cost Rationality: In the absence of unified, reliable, and comparable public information, access to ESG data requires reliance on external information sources, which entails disproportionate and high costs. LINCE CAPITAL, therefore, considers that excessive and unwarranted costs are associated with taking into account the negative impacts of investment decisions on sustainability factors in its investment decision-making process.

– Constitutive Documents: The constitutive documents of the managed Venture Capital Funds (FCRs) do not impose any care or diligence with regard to the adverse impacts of investment decisions on sustainability factors in the investment decision-making process. LINCE CAPITAL, therefore, believes that participants do not expect consideration of adverse impacts of investment decisions on sustainability factors within its investment decision-making process.

Lisboa, 20 de maio de 2024