ESG Disclosures in accordance with SFDR



ESG Disclosures in accordance with SFDR

In its capacity of alternative investment fund manager ('AIFM'), We are Jane Partners (the “Manager”) is subject to the disclosure obligations relating to environmental, social and governance (“ESG”) matters as set forth in:

  • Regulation (EU) no. 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”);
  • Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying the details of the content and presentation of the information in relation to the principle of ‘do no significant harm’, specifying the content, methodologies and presentation of information in relation to sustainability indicators and adverse sustainability impacts, and the content and presentation of the information in relation to the promotion of environmental or social characteristics and sustainable investment objectives in precontractual documents, on websites and in periodic reports (“RTS”); and
  • Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment and amending Regulation (EU) 2019/2088 (“TR”).

The Manager may update this information at any time and will in such event publish a clarification on such amendment on this website.

  1. Promotion of social sustainability factors

The Manager promotes social characteristics and considers itself as a Light Green Fund under art. 8 of the SFDR regulation.

The Manager confirms to integrate social & governance sustainability factors into its investment decision procedure. Every new investment opportunity is screened on its gender balance. Due diligence on an investment will only start if there is either a female CEO or if the company has a gender balance of at least 50% female employees.

On a governance level, the Manager will make sure, there is always female representation on the board of the investee companies.

The Manager will make sure the investee companies respect human rights, anti-corruption and anti-bribery matters.

The Manager does however not integrate environmental sustainability risks into its investment decision procedure, as referred to in article 3 SFDR. These risks and the likely impacts of them on the returns of the fund managed by the Manager are not formally assessed.

The Manager acknowledges that environmental related events or conditions could potentially have an impact on the value of the investments made on behalf of fund managed by the Manager.

Hence, the investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

  1. No consideration of adverse sustainability impacts of investment decisions

The Manager does not consider adverse sustainability impacts of its investment decisions, as referred to in article 4, §1, (b) SFDR. This means that adverse impacts on climate and other environment-related indicators (including, greenhouse gas emissions, biodiversity, water and waste) are not taken into account. However, indicators for social and employee, respect for human rights, anti-corruption and anti-bribery matters are taken into consideration in the Manager’s investment decisions.


  1. Integration of sustainability risks into remuneration policies

As a sub-threshold manager of alternative investment funds, the Manager does not have an obligation to have a formal remuneration policy in accordance with article 40 and following of the Belgian law of 19 April 2014 on alternative entities for collective investments and their managers. Consequently, sustainability risks are not integrated in the Manager’s remuneration policy.