Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)
Date of publication: 10.03.2021
Date of update: 22.11.2022; addition of Armira Growth Fund I GmbH & Co. KG and implementation of
required language and structure pursuant to the RTS
I. Sustainability risks
Armira Administration GmbH (LEI: 391200ZRDDLOLSDEE690) and Armira Growth Management GmbH
(LEI: 391200PDU5RZVDPED134, Armira Administration GmbH and Armira Growth Management GmbH
hereinafter jointly referred to as “Armira”) consider sustainability risks as part of their investment decisionmaking
process. Sustainability risks are environmental, social or governance events or conditions, the
occurrence of which could have an actual or potential material adverse effect on the value of the investment.
Armira considers sustainability risks as part of its due diligence process prior to any investment. This also
includes an assessment of sustainability risks. Such assessment is being conducted through an informal
process as appropriate in light of the circumstances of the individual case. The results of such assessment are
taken into account when the investment decision is being taken. However, Armira remains free in its decision
to refrain from investing or to invest despite sustainability risks, in which case Armira can also apply measures
to reduce or mitigate any sustainability risks. At all times, Armira will apply the principle of proportionality
taking due account of the strategic relevance of an investment as well as its transactional context.
II. No consideration of adverse impacts of investment decisions on sustainability factors
Armira does not consider adverse impacts of its investment decisions on sustainability factors as defined in
the SFDR. Sustainability factors are environmental, social and employee concerns, respect for human rights
and the fight against corruption and bribery. Given that the SFDR, the Regulation (EU) 2020/852
(“Taxonomy”) and the accompanying Regulatory Technical Standards (Delegated Regulation
(EU) 2022/1288, “RTS”) are relatively new legislative acts, there is very little or no practical experience or
practice with regard to the application of their respective provisions. Therefore, substantial legal uncertainties
would remain when applying those provisions to the strategies pursued by Armira. If and to the extent that
the legal uncertainties will be resolved and a practicable market and administrative practice will evolve in this
regard, Armira will evaluate considering principal adverse impacts of its investment decisions as defined in the
SFDR and with regards to the indicators listed in Annex I of the RTS.
Apart from that, Armira already collects its own set of KPIs across all portfolio companies on a voluntary basis.
The KPI set comprises both several indicators as set out in Annex I of the RTS as well as self-defined KPIs
according to Armira standards.
III. Remuneration disclosures
As a registered alternative investment fund manager within the meaning of section 2 (4) of the German
Investment Code (Kapitalanlagegesetzbuch, “KAGB”), Armira does not have and does not need to have a
remuneration guideline or policy in accordance with the requirements of the KAGB.
IV. Sustainability-related disclosures
Financial product: Armira Growth Fund I GmbH & Co. KG (the “Fund” / der “Fonds”)
The Fund considers certain environmental and/or social characteristics as part of its investment decisions and
monitoring processes but does not seek to make sustainable investments as defined in the SFDR. The
consideration of environmental and/or social characteristics is carried out both before and after an investment.
For this purpose, information is initially and regularly obtained from the portfolio companies by means of
qualitative queries. The Fund incorporates exclusion (negative screening) aspects during the decision-making
process. Thereby the Fund considers several ESG themes to be the key to responsible investing. The actions
and decisions described in the following section are each made by Armira Growth Management GmbH for and
on behalf of the Fund.
Der Fonds berücksichtigt bestimmte ökologische und/oder soziale Merkmale im Rahmen seiner
Investitionsentscheidungen und Monitoring-Prozesse, strebt aber keine nachhaltigen Investitionen im Sinne
der SFDR an. Die Berücksichtigung von Umwelt- und/oder Sozialmerkmalen erfolgt sowohl vor als auch nach
einer Investition. Zu diesem Zweck werden zunächst und regelmäßig Informationen von den
Portfoliounternehmen durch qualitative Abfragen eingeholt. Der Fonds bezieht Exklusionsaspekte (negatives
Screening) in seinen Entscheidungsprozess ein. Dabei betrachtet der Fonds mehrere ESG-Themen als Schlüssel
für verantwortungsvolles Investieren. Die in diesem Abschnitt beschriebenen Handlungen und Entscheidungen
erfolgen jeweils durch Armira Growth Management GmbH für den Fonds.
No sustainable investment objective
The Fund promotes environmental or social characteristics, but does not have as its objective sustainable
Environmental or social characteristics of the financial product
The Fund promotes environmental and/or social characteristics by implementing certain investment exclusions
(see section ‘Investment strategy’) during the decision-making process.
The purpose of the Fund is to build, hold and manage (including to divest) a portfolio of equity and equityrelated
investments in portfolio companies. The Fund will conduct investments in Portfolio Companies from all
sectors with innovation capacity and growth potential. As such, investments are expected to be spread across
a wide range of economic activities. The Fund intends to make its initial investments in particular, without
limitation, in the growth stage financing rounds of the respective portfolio company. The Fund shall focus its
investments primarily on companies that have their registered office or center of business activities primarily
in Europe, with a focus on the DACH region (i.e., Germany, Austria and Switzerland).
The Fund is bound by the investment restrictions and limitations set out in the Fund’s limited partnership
agreement and shall procure that such requirements, restrictions and limitations are complied with at all times.
In particular, the Fund will screen each investment opportunity against its investment exclusions and no
investments will be made in the area of such exclusions.
The Fund shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to
companies, including portfolio companies, or other entities whose business activity consists of:
a) Any illegal economic activity (i.e., any production, trade or other activity, which is illegal under
the laws or regulations applicable to the Fund or the relevant portfolio company);
b) The production of, and trade in, tobacco, non-alcoholic recreational drugs and related products
as well as distilled alcoholic beverages;
c) The financing and production of, and trade in, weapons of any kind;
d) Retail banking;
e) Oil and gas or metals and mining exploration, extraction or operations;
f) Data programs intended to enable to illegally (i) enter into electronic data networks, or (ii)
download electronic data;
g) Casinos and gambling;
h) Adult Entertainment.
Good governance practices are assessed through an informal process as appropriate in light of the
circumstances of each individual case. Such practices include, in particular, sound management structures,
employee relations, remuneration of staff and tax compliance within the portfolio companies. Moreover, the
Fund will conduct regular monitoring of the good governance practices in its portfolio companies during the
holding period. If the Fund becomes aware of severe governance issues, it will investigate them and work with
all parties involved to find an appropriate solution.
Proportion of investments
The Fund will invest fully in line with its investment strategy and investment restrictions, i.e., will only make
investments which are aligned with its environmental or social characteristics (i.e., its investment exclusions).
The Fund does not make and does not intend to make sustainable investments within the meaning of
article 2 no. 17 SFDR or environmentally sustainable investments within the meaning of Art. 3 Taxonomy;
hence, no portion of its investments will be aligned with the Taxonomy.
Monitoring of environmental or social characteristics
The Fund has an increased awareness on the impact of environmental or social characteristics on risk
management and thus on the value potential of investments. In order to monitor the environmental or social
characteristics promoted by the Fund (i.e., its investment exclusions), the Fund consults with the portfolio
companies in regular intervals and will carry out further checks in order to identify potential issues with such
characteristics. Therefore, the Fund monitors compliance with its environmental or social characteristics (i.e.,
its investment exclusions) on an ongoing basis. External monitoring mechanisms are not in place.
Methodologies for environmental or social characteristics
The Fund applies qualitative assessments with regard to its environmental or social characteristics (i.e., its
The Fund conducts an initial assessment of the promoted environmental or social characteristics in the course
of its due diligence. Based on the results of such assessment the Fund identifies pre-investment whether the
environmental or social characteristics promoted by the Fund are met. During the holding period, the so
conducted assessment forms the basis to measure and monitor if the characteristics are continuously being
Data sources and processing
In order to attain each of the environmental or social characteristics promoted by the Fund (i.e., its investment
exclusions) the Fund obtains the relevant data from its (potential) portfolio companies through an informal
process in the course of the due diligence conducted prior to each investment. Moreover, during the holding
period, the Fund relies on publicly available date to continuously check the compliance with the investment
exclusions. Hence, most data is obtained from the (potential) portfolio companies; however, a part of the
relevant data may be estimated or supplemented by information publicly available. An internal or external
review or verification of the information obtained will be carried out if misrepresentations are suspected.
Limitations to methodologies and data
The information collected from the (potential) portfolio companies through the informal process carried out
by the Fund is internally or externally verified only if and to the extent misrepresentations are suspected. Thus,
it cannot be ruled out completely that false information may remain undetected in certain cases. As the Fund’s
investments are made for several years, the Fund considers it a priority to establish and maintain a trustful
working relationship with its portfolio companies in order to ensure compliance with the environmental or
social characteristics promoted by the Fund (i.e., its investment exclusions). Further limitations, in particular
with regard to the accuracy of the data and reliability of the data sources used, are not apparent at this time.
An initial assessment of how an investment relates to the environmental or social characteristics promoted by
the Fund (i.e., its investment exclusions) is carried out as part of the due diligence through the informal
process and, where required based on the inherent ESG risk of the portfolio company, through an enhanced
analysis. As a rule, purely qualitative statements of an environmental or social nature or relating to corporate
governance are requested from the portfolio companies and then taken into account in the investment
decision-making process. An internal or external review or verification of the information obtained will only be
carried out if misrepresentations are suspected.
Engagement is not part of the environmental or social investment strategy of the Fund.
Designated reference benchmark
No index has been designated as a reference benchmark to meet the environmental or social characteristics
promoted by the Fund.