EU FSDR disclosure

HarbourVest – SFDR website disclosures

The present statement contains, in particular, the disclosures which are required to be made on this website by HarbourVest Partners (Ireland) Limited (“HarbourVest Ireland”), as a “financial market participant”, in respect of the AIFs under its management (the “AIFs”) under the Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (the “Sustainability Disclosures Regulation” or “SFDR”).

HarbourVest Ireland delegates the portfolio management of the AIFs to its affiliate, HarbourVest Partners LP (“HarbourVest”). HarbourVest is an independent, global private markets investment specialist with over 35 years of experience and more than $98 billion in assets under management and offers investors investment opportunities through primary fund investments, secondary investments, and direct co-investments in comingled funds or separately managed accounts.

Transparency of sustainability risk policies at entity level

(article 3 of the Sustainability Disclosures Regulation)

HarbourVest, as the portfolio manager of the AIFs, views responsible investing, or the incorporation of environmental, social, and governance (“ESG”) factors into investment and management decisions, as an important part of its business. HarbourVest has been a proud signatory to the Principles for Responsible Investment (PRI) since 2013 and strongly believes that ESG risks can affect the performance of investment portfolios, to varying degrees, across companies, sectors, and time periods.

As an institutional investor, HarbourVest’s commitment to ESG integration is grounded in its conviction that the policies and processes of the managers that the AIFs invest with to manage ESG risk can be an indicator for financial performance.  HarbourVest has integrated ESG procedures within each of its investment strategies to support sound investment decision-making, which is at the core of how it seeks to create compelling, risk-adjusted returns for investors.

HarbourVest’s policy on the integration of sustainability risks in its investment decision making process can be found here.

Transparency of adverse sustainability impacts at entity level

(article 4 of the Sustainability Disclosures Regulation)

HarbourVest Ireland does not currently intend to publish a statement on its consideration of the adverse impacts of investment decisions on sustainability factors in the manner set out in article 4 of the SFDR.  Whilst its affiliate HarbourVest integrates sustainability risks  in its investment process, as a fund of fund manager  making primary investments, secondary investments and minority non-control direct investments, it has limited control over and access to data from underlying fund managers and cannot provide the information in relation to its consideration of the adverse impacts of its investment decisions on sustainability factors in the manner set out in the final Regulation on ESG disclosures published by the European Commission on 6 April 2022. HarbourVest Ireland expects to keep this position under review by reference to applicable market developments and future availability of information.

Transparency of remuneration policies in relation to the integration of sustainability risks

(article 5 of the Sustainability Disclosures Regulation)

Both HarbourVest Ireland and HarbourVest require relevant individuals to adhere to their policies and processes regarding the integration of environmental, social and governance obligations.  Specific ESG-related metrics may be set for relevant individuals based on the priorities and objectives for that individual, as determined by their manager and functional leaders. In addition, HarbourVest considers its commitment to ESG integration as material to investment performance over the long term and aligned with its remuneration structure which focuses on long term fund performance.

Disclosure in relation to AIFs that are subject to Article 8 or Article 9 of the Sustainability Disclosures Regulation

(link to disclosures required under article 10 of the Sustainability Disclosures Regulation)

HarbourVest Ireland publishes and maintains the information required under Article 10 of the Sustainability Disclosures Regulation for each of the AIFs in scope of Article 8 or Article 9 of the Sustainability Disclosures Regulation through its Intralinks and Investor Portal. Access to HarbourVest’s Intralinks and Investor Portal is made available to certain potential and existing investors in the AIFs.

Date of last review:   June 2022.