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Sustainability Disclosures under SFDR – Principal Adverse Impact Statement
Disclosure pursuant to Article 4(1)(b) of Regulation (EU) 2019/2088 on sustainability ‐ related disclosures in the financial services sector ("SFDR")
In accordance with Article 4(1)(b) of the Sustainable Finance Disclosure Regulation (EU) 2019/2088 ("SFDR"), AYMO GP S.à r.l. makes the following statement in respect of its roles as: 1. Registered alternative investment fund manager (AIFM) of AYMO Accelerator Fund SCSp, and 2. General partner of AYMO Fund SCSp, for which an external AIFM has been appointed (AYMO Fund SCSp and AYMO Accelerator Fund SCSp together referred to as the "Funds"). AYMO GP S.à r.l. hereby states that it does not consider the principal adverse impacts ("PAIs") of investment decisions on sustainability factors as defined in Article 4(1)(a) of SFDR. The principal reasons for not considering such adverse impacts are as follows: 1. Proportionality and size of the manager: AYMO GP S.à r.l. qualifies as a sub-threshold AIFM under Article 3(2) of the AIFM Directive and is therefore not subject to the full scope of SFDR obligations. As a smaller manager, the implementation of the detailed data collection, monitoring, and reporting requirements under the PAI regime would not be proportionate given the nature and scale of our operations. 2. Data limitations: The investment strategies of the Funds focus on early-stage and growth-stage companies, many of which do not yet report in a standardized way on sustainability indicators or provide sufficient data to enable a reliable and consistent assessment of principal adverse impacts. 3. Focus on qualitative ESG integration: Although the Funds do not consider PAIs on a quantitative basis, ESG risks and opportunities are integrated into the investment decision-making process through qualitative assessment, ongoing dialogue with portfolio companies, and responsible ownership practices. AYMO GP will continue to monitor regulatory developments and evolving market practices and may reconsider its position on the consideration of PAIs in the future.
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