1) ESG policy, objectives & commitments
2) Code of ethics
3) Governance
4) Net zero strategy
5) ESG annual report
6) SFDR (Sustainable Finance Disclosure Regulation)
7) UNPRI




SFDR (Sustainable Finance Disclosure Regulation)

SFDR, which came into effect in March 2021, is an EU regulation aimed at promoting sustainability in financial markets. It requires financial market participants, including real estate funds, to disclose information about their ESG policies, processes, and the sustainability impact of their investments. Compliance with SFDR helps investors make more informed decisions, fosters responsible investment practices, and contributes to the overall sustainability objectives of the European Union.

Gain Investor Trust: Being SFDR compliant showcases our commitment to transparency and accountability. By disclosing our ESG policies and the impact of our investments, we build trust with investors who seek responsible opportunities.

Attract a Diverse Investor Base: SFDR compliance opens doors to a broader range of investors. Institutional investors, in particular, have stringent ESG requirements. By aligning with SFDR, we welcome these investors and expand our potential investor pool, increasing our market competitiveness.

Mitigate Risks: SFDR compliance means taking a proactive approach to identify and manage ESG risks. By conducting thorough due diligence on climate, social, and governance factors, we safeguard our investments against potential vulnerabilities. This protects our fund's long-term performance and ensures resilience in a changing world.

Align with Global Standards: SFDR aligns with internationally recognized frameworks like the UN SDGs and TCFD recommendations. By complying with SFDR, we demonstrate our commitment to these global sustainability objectives. It's not just about ticking boxes; it's about leading the way toward a more sustainable future.

Stay Ahead of Regulations: SFDR is not just a choice; it's a regulatory requirement. Non-compliance can result in penalties and reputational damage. By being SFDR compliant, we stay ahead of the game, meet our legal obligations, and ensure a smooth journey in a rapidly evolving regulatory landscape.

SFDR compliance is not just a checkbox exercise. It's a driving force that propels us toward sustainable success. By embracing SFDR, we attract investors, manage risks, and contribute to a better future.

ART 3

- Extract of art 4.1 Fund IV PPM –ESG Risk : integration of sustainability risks art 3

“Blue Colibri may use third party ESG data, when considering as part of its investment process the Sustainability Risks and their potential impact on the returns. Third party ESG data may be difficult to obtain and/or incomplete, estimated, based on subjective assumptions, out of date or otherwise inaccurate. In particular, data may be more readily available and/or reliable in certain countries and/or markets where the Fund invests, making direct comparison of the Sustainability Risks relevant to different Investments difficult. In addition, Blue Colibri’s respective own due diligence relies on the availability and accuracy of various sources, such as company disclosures and other third party information, which often include forward looking statements of intent and are not necessarily fact-based or objectively measureable. Blue Colibri is also dependent on the subjective judgements on Sustainability Risks of its relevant investment team. Each of the foregoing might mean that a Sustainability Risk relevant to a particular Investment may not be identified or thoroughly or accurately assessed prior to the Investment being made and losses may be suffered as a result.“

Disclosures under SFDR and Taxonomy Regulation

Integration of ESG Risks

  • 7.17  Blue Colibri believes that consideration of ESG Risks as part of the due diligence process carried out on Investments is a necessary aspect of evaluating the risk associated with the relevant investment and, accordingly, the return to the Fund. When carrying out due diligence Blue Colibri relies on information provided to it by the Advisers. The process set out below takes into consideration the involvement of the Advisers in the due diligence process.

  • 7.18  ESG integration is driven by taking into account material ESG Risks as part of the Blue Colibri’s overall investment, risk assessment and due diligence process.

  • 7.19  As part of the due diligence process, Blue Colibri will assess whether the Investments are viable. This can be done by submitting appropriate documents e.g. (third-party) labels or certificates.

  • 7.20  Any related or heightened ESG Risks flagged by the due diligence process are documented in the investment memorandum which is prepared for the Investment Committee. The Investment Committee will consider the content of the investment memorandum and assess whether the due diligence, including the due diligence on ESG Risks, has been satisfactorily completed and will discuss any material ESG Risks which have been flagged and will make a final investment decision. One of the grounds on which the Investment can be vetoed is ESG Risks.

 For each investment process, BCC relies on a ESG Due Diligence checklist

 All investment decisions are based on investment proposal which access a wide range of ESG risks and opportunities

 ESG risk matrix yearly updated by ESGSC (risk typology…)

ART 4

After carefully evaluating the requirements of the PAI regime in Article 4 SFDR alongside its advisors, the main reason for not considering adverse impacts of investment decisions on sustainability factors is the lack of further information and relevant data of the required quality to identify, adequately assess and weight sustainability-related PAI.

Blue Colibri Capital will continue reviewing the situation on a regular basis and may decide on this basis on the possibility of taking into account PAI of investment decisions on sustainability factors in the future, while considering fund documentation carefully.

Blue Colibri Capital is supportive of the policy aims of the PAI regime, to improve transparency to clients, investors, and the market, as to how financial market participants integrate consideration of the adverse impacts of their investment decisions on sustainability factors. However, taking account of the company’s size, we consider that it would be disproportionate to comply with the specific regime in the SFDR.

In addition, the Firm is also concerned about the lack of reasonably priced / readily available data to comply with many of the technical reporting requirements of the PAI regime, as we believe that issuers and market data providers are not yet ready to make available all necessary data for the PAI regime.

ART 5

Remuneration policy

The purpose of Blue Colibri Capital remuneration policy is to lay down the principles governing how the remuneration of the AIFM’s employees shall be established, applied and monitored.

The policy and the subsequent measures have been drafted to be appropriate to the size of BCC and of the funds it manages, the internal organisation, the nature, scope and complexity of the activities performed and its human resources.

The overall philosophy of the Policy is to promote sound and effective risk management, as well as a long-term perspective, and to discourage excessive risk-taking by the BCC’s employees. In particular, consideration has been given to the business strategy, objectives, values and interests of BCC and the Funds, in accordance with the conflict of interests’ policy.

BCC has decided to opt for the application of the proportionality principle at the level of the AIFM with respect to the different characteristics of the AIFM in terms of the size, internal organization and nature, scope and complexity of its activities and with respect to the different categories of staff.

Senior management and employees are collectively responsible for implementing ESG throughout the organisation in particular the investment / Asset / fund management process. Clear yearly objectives are set and are taken into account in the variable remuneration. Based on each individual role in the company.