The Disclosure Regulation aims to provide more transparency in terms of environmental and social responsibility within financial markets, in particular through the provision of information on the sustainability of financial products (integration of risks and negative impacts in terms of sustainability ). Its objectives are to ensure alignment between commercial documents and the reality of practices, to ensure the comparability of products in these terms and to orient private investments towards more responsible investments. This regulation intervenes at the level of the entities (management companies, investment companies, financial advisers), but also at the level of the products. The publications of the companies and the pre-contractual documents of the products will be modified as a result.
The Disclosure Regulation firstly requires defining the classification of each product according to its characteristics. The definition of each of these categories:
NextStage AM's mission is to invest sustainably and responsibly alongside talented entrepreneurs at the head of growth SMEs and ETIs, champions of their market.
Taking into account the management process implemented in our funds, we have classified the funds as follows according to article 6 and article 8. No funds have at this stage been identified as falling under article 9.
Since the products have been classified in accordance with the provisions of the Disclosure Regulation, the regulatory documentation has been updated accordingly and each investor may consult the related amended documentation:
Sustainability risks are defined by the Disclosure Regulation on the Disclosure of Sustainability Information in the Financial Services Industry as "an event or situation in the environmental, social or governance field which, if occurs, could have a material adverse effect, actual or potential, on the value of the investment ”.
NextStage AM integrates sustainability risk management processes into its management. These processes evolve regularly through the strengthening of the governance of ESG subjects, procedures and associated tools.
The current modalities for integrating sustainability risks into NextStage AM's activities are as follows:
Among the seven partners of NextStage AM, two are in charge of supervising ESG issues. They cover the ESG subject in the various governance bodies, and in the daily investment activity of NextStage AM.
NextStage AM actively participates in several French and international initiatives directly linked to ESG. By participating in these initiatives, NextStage AM affirms its commitment to environmental, social and governance issues, and strengthens dialogue and the sharing of best practices between investors.
NextStage AM integrates an ESG approach as part of its investment activities in the unlisted, at the different stages of the investment cycle:
In view of the entry into force of the Energy Climate Law n ° 2019-1147, which amends the Law on energy transition for green growth and its article 173, NextStage AM reserves the right to gradually strengthen the considers the risks associated with climate change and biodiversity in its investment practices.
As part of the stock selection process, NextStage AM performs an extra-financial analysis on various ESG subjects, in particular management (quality of managers, motivation instruments, equity participation, convergence of interests with shareholders, independence of directors), HR management (remuneration policy, association with capital) and intangible capital (brands, patents, market shares, etc.).
In line with its commitment to responsible investment, NextStage AM has structured a list of negative impact sectors in which it prohibits all investment. This list can be accessed here.
NextStage AM's remuneration policy has been reviewed to strengthen consideration of sound and effective risk management, particularly around the consideration of sustainability risks. We thus aim to ensure that the remuneration structure does not encourage excessive risk-taking in terms of sustainability, and that it is linked to risk-adjusted performance, within the meaning of the Disclosure Regulation.
Article 4 of the Disclosure Regulation on the Disclosure of Sustainability Information in the Financial Services Sector provides for greater transparency on the negative impacts of investment decisions. NextStage AM does not currently take these impacts into account for the following reasons:
• NextStage AM is not subject to this provision, not exceeding the threshold of five hundred employees.
• The availability and quality of data are currently limited.
• The implementation of the regulatory framework on this subject is still incomplete.
Consequently, NextStage AM considers that its governance of the ESG subject, its procedures and its tools (see also the statement concerning the integration of sustainability risks) enable it to understand the impact of its investment decisions on the factors sustainability more adequately than through the elements presented in Article 4 of the Disclosure Regulation.
Depending on the evolution of the regulatory framework, the improvement, availability and quality of data, NextStage AM reserves the right to take into account in the future the negative effects of investment decisions on the factors sustainability within the meaning of article 4 of the Disclosure Regulation.
The variable component of remuneration is determined based on ESG criteria, defined precisely in the full version of the Remuneration Policy, in particular:
The remuneration policy is available here.
Due diligence policies
ESG NextStage AM Charter
Report Article 29 LEC
Voting policy: shareholder engagement policy (12.2022)
Statement on the main negative impacts of investment decisions on sustainability factors
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