ESG integration

1.- Policy objective

This document describes MOIRA CAPITAL PARTNERS, SGEIC, S.A.’s (hereinafter, the “Company”) policy on integrating environmental, social and corporate governance criteria, known as ESG criteria (hereinafter, “ESG”), defining the weight of each of these factors in the investment decision-making processes in financial instruments/investee companies that the Company must carry out in the performance of its activities as a venture capital entity (ECR) manager.

The Sustainable Development Goals (2015–2030), adopted on 25 September 2015, also known by their acronym SDGs, are an initiative promoted by the United Nations to continue the development agenda after the Millennium Development Goals (MDGs), and constitute a course of action for the Company in achieving ESG factors.

This policy also responds to and establishes the scope of the obligations regarding its publication, in compliance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector.

At present, the Company has decided not to integrate ESG criteria into its investment decision-making processes, as detailed in section 3 of this policy.

2.- Definitions
ESG factors

ESG factors are understood as any information related to environmental and social matters, as well as matters relating to staff, respect for human rights and the fight against corruption and bribery:

 

• The environmental factor (E), to make decisions based on how companies’ activities affect the environment. It focuses on environmental reporting and companies’ environmental impact, as well as the efforts made by companies to reduce pollution levels or carbon emissions. It would include waste management, water management and the use of other environmental resources.

• The social factor (S), to take into account the impact that the entity’s activities have on the community, for example in terms of diversity, governance, human rights or healthcare, as well as the links established with the community (corporate citizenship and philanthropic initiatives).

• The governance factor (G), which studies the impact of shareholders and the management of entities, and is based on issues such as the structure of boards of directors, executive remuneration and shareholders’ rights, as well as transparency and the relationship between shareholders and the management of the entities.

 

Sustainable investments

Sustainable investments are considered to be investments in:

 

• An economic activity that contributes to an environmental objective, measured, for example, through key resource-efficiency indicators relating to the use of energy and renewable energy, consumption of raw materials, water and land, waste production and greenhouse gas emissions, and impact on biodiversity, the circular economy, or

• An economic activity that contributes to a social objective and, in particular, any investment that helps to combat inequality.

 

Any investment that strengthens social cohesion, social integration and labour relations, or any investment in human capital or in economically or socially disadvantaged communities; provided that such investments do not significantly harm any of these objectives and the beneficiary companies follow good governance practices, in particular with regard to having sound management structures, employee relations and relevant staff remuneration, and complying with tax obligations.

It therefore consists of adding to the financial analysis an analysis of the risks and opportunities for the entity arising from environmental, social and corporate governance aspects, in order to support better decision-making.