In order to comply with the sustainable finance disclosure regulation (SFDR) , Collective Spark Management B.V. (Collective Spark) makes the following disclosures.

Integration of sustainability risks
A sustainability risk (article 6 (1) (a) SFDR) means:
“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”.

Before any investment decisions are made on behalf of a fund that Spark Collective manages, an investment decision process is followed. Part of the investment decisions process is that Collective Spark aims to assess the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are considered by Collective Spark when making investment decisions where needed.

No consideration of sustainability adverse impacts
In accordance with article 4 sub 1 (b) of the SFDR, Collective Spark states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the SFDR.

At this stage Collective Spark does not consider the adverse impacts of its investment decisions on sustainability factors, (i) because Collective Spark could not reasonably gather and/or measure all the relevant data of the portfolio companies of Collective Spark, taking into account reasonable cost for clients and investors and (ii) due to the small size of the organisation of Collective Spark, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden in connection therewith would not be proportional.

Collective Spark continues to closely monitor the market developments (including the level of availability of the data) as well as the regulatory developments. Collective Spark will at least on an annual basis review whether and when to comply with article 4 sub 1 (a) of the SFDR.