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Sustainable
Finance
Disclosure

Behind Game Group. A limited company registered in Amsterdam (company number X) with its registered office at

555 Keizersgracht, 1017 DR,

Amsterdam, Netherlands.

 

Authorised and regulated by the Financial Conduct Authority (number X) FCA COBS Rule 2.2.3R requires FCA authorised firms to disclose whether they conform to the requirements of the UK Financial Reporting Council’s Stewardship Code (the “Code”). Adherence to the Code is voluntary. While the Behind Game Group supports the principles of the Code, it does not consider it appropriate to conform to the Code at this time.

1. Sustainable Finance Disclosure

The below disclosures are applicable to Behind Game Group (“BGG”), an Holland-based investment firm operating under the MiFID II framework. It is our understanding, that both Behind Game Group (“BGG”) as a non-EU investment firm and Behind Game Group Manager (“BGGM”) as a non-EU alternative investment fund manager, are not subject to the entity level regulatory requirements of the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (“SFDR”). Although our organisation is spread geographically, we operate as one ‘Behind Game Group’, where sustainability is an important factor in our decision-making process. We have therefore chosen to include entity level disclosures for BGG and BGGM on a voluntary basis.

Article 3(1) – Entity Level Sustainability Risk Disclosure

 

Behind Game Group considers sustainability risks and factors during the investment process, as outlined in our Responsible Investment Policy (“Policy”). The Policy outlines Behind Game Group’s approach to the assessment and management of environmental, social and governance (ESG) issues during the investment process. The Policy is applicable across BGG, MBGG and BGM, including future managers and successor funds, all staff and all investments made since 2022. The Policy outlines the approach we take to investing responsibly across the Behind Game Group funds and at Behind Game Group as a firm.

The Policy sets out the principals to assess and manage sustainability risks when making an investment decision, and for ongoing management of the portfolio. Behind Game Group will always assess a target company’s ESG risks and opportunities during the due diligence process. In situations where ESG risks or opportunities require further scrutiny, external specialists will be instructed to undertake detailed ESG, or specific topic, assessments. Should material findings be identified, they will be analysed and presented by the deal team to the Investment Committee in the specific ESG section of the Investment Memorandums. If the risks identified during the due diligence process are too great and cannot be appropriately mitigated, Behind Game Group will not pursue the investment.

 

My Body Group has an ESG Committee comprising four Partners and the Head of Sustainability. The Committee meets monthly to monitor progress and members are responsible for the implementation of the Policy.

All Investment Professionals are required to follow the Policy and to consider relevant ESG factors as part of their pre-investment and portfolio monitoring responsibilities. Investment Professionals receive regular training on the Policy, accompanying ESG tools and relevant ESG topics.

Article 4(1)(a) – Principal Adverse Impacts (PAI) Disclosure

 

Behind Game Group engages with portfolio companies to understand and monitor sustainability factors on a regular basis. Such factors are not currently assessed as prescribed by the draft Regulatory Technical Standards (RTS) of the SFDR. Instead, Behind Game Group uses sustainability factors which are appropriate and material to the sectors we invest in and the companies within our portfolio. However, we will continue to closely monitor the development and finalisation of the RTS and are committed to reviewing our position once the RTS are finalised.

Article 5(1) – Entity Level Remuneration Policy Disclosure

 

Behind Game Group considers sustainability risks in its remuneration policies to ensure sound and effective risk management.

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