These disclosures are made at manager level pursuant to Article 3(1), Article 4(1)(b) and Article 5(1) of Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (the “SFDR”).
01 / SFDR
Identification of the Manager and scope of disclosure
Manager: EQT Ventures s.r.o., with its registered office at Hviezdoslavovo námestie 15, 811 01 Bratislava - Staré Mesto district, Slovak Republic, company ID: 50 532 481, entered in the Commercial Register of Bratislava III Municipal Court, Section Sro, insert no. 114294/B (the “Manager”).
Fund: ZEPHYR AIF a. s., with its registered office at Hviezdoslavovo námestie 15, 811 01 Bratislava - Staré Mesto district, Slovak Republic, company ID: 51 145 979, entered in the Commercial Register of Bratislava III Municipal Court, Section Sa, insert no. 6679/B, an alternative investment fund (AIF) (the “Fund”).
The Manager manages ZEPHYR AIF a. s. The Manager is a registered alternative investment fund manager entered in the register of registered alternative investment fund managers maintained by Národná banka Slovenska (the National Bank of Slovakia) under registration number 0010. It was established exclusively to manage a single fund and does not provide investment advice. These disclosures are made at Manager level and relate solely to its activities in managing the Fund.
The Fund is not a closed-ended fund for a limited circle of investors. The fundamental rights and obligations relating to the management of the Fund arise from the contractual documentation governing the relationship between the Manager and the Fund. The Fund is established for an indefinite period; its duration is not limited by investor agreements.
02 / SFDR
Transparency of sustainability risk policies
Article 3(1) SFDR
Sustainability risks and their assessment
A sustainability risk is an environmental, social or governance event or condition that could have an actual or potential material negative impact on the value of an investment. ESG risks comprise environmental, social and governance risks.
The Manager assesses relevant sustainability risks individually, taking into account the nature of the investment, its risk profile and the availability of data. It does not use a uniform ESG scoring system or predetermined weightings for sustainability factors. The scope and intensity of the assessment are proportionate to the size of the portfolio companies, the scope and nature of their activities, the investment strategy and the available information.
Investment strategy and decision-making
The Fund has a broad sector focus. Its investment strategy prioritises agriculture and food production, consumer goods and services, software and data intelligence, information technology and waste management. Within these areas, it also considers recycling, solar systems and innovative technologies. The strategy’s geographical focus covers the Slovak Republic, the Czech Republic and Hungary.
The Fund’s portfolio includes investments in energy, industry and real estate in Central Europe. The strategy includes the consolidation and restructuring of assets and their financing, long-term holdings in strategic and dividend-generating investments, the development and subsequent sale of assets, and the pursuit of investment opportunities to optimise returns.
The Manager actively manages the Fund in accordance with its investment strategy. Investment decision-making covers investment preparation, the management and monitoring of existing investments, their holding, conversion, realisation or distribution, and the timing of disposals. Relevant sustainability risks are assessed individually in relation to these activities.
The Manager is responsible for investment decisions and acts in accordance with applicable legislation, the investment strategy, the purpose of the Fund and the relevant contractual documentation. Decisions are based primarily on financial, economic, technological and market criteria; relevant sustainability risks are assessed as part of that decision-making process.
Data availability and investment due diligence
For individually structured investments, the availability of standardised, comparable or audited ESG data may be limited. When assessing investments, the Manager takes account of appropriate, reliable and verifiable information that is available.
The Manager monitors and assesses risks arising from developments in environmental policy and legislation that may affect investment returns. Matters considered include delayed or insufficient progress towards environmental protection or sustainable development objectives. As part of investment due diligence, the Manager considers relevant sustainability factors where they may have an actual or potential material negative impact on the value of the investment or the viability of the target company, such as compliance with environmental legislation.
The Manager requires portfolio companies to comply with standards of corporate governance, transparency and conflict-of-interest prevention. Emphasis is also placed on compliance of their business activities with applicable legislation. Governance transparency is also considered when conducting due diligence on a specific investment.
If an individual investment assessment identifies an elevated sustainability risk that may affect the value or viability of the investment, the Manager may take appropriate measures, including divestment. In selecting measures, it takes account of its contractual powers and their legal and practical feasibility.
03 / SFDR
No consideration of adverse impacts of investment decisions on sustainability factors
Article 4(1)(b) SFDR and Article 12 of Commission Delegated Regulation (EU) 2022/1288
In managing the Fund, the Manager currently does not consider the adverse impacts of its investment decisions on sustainability factors pursuant to Article 4(1)(b) SFDR.
Sustainability factors include environmental, social and employee matters, respect for human rights, and anti-corruption and anti-bribery matters. PAI refers to the principal adverse impacts of investment decisions on sustainability factors. Sustainability risk assessment considers the impact of such risks on the value of an investment; PAI concerns the adverse impacts of investment decisions on sustainability factors.
Reasons for not considering adverse impacts
The reasons for not considering adverse impacts are the limited availability of comparable and verifiable data on the adverse impacts of investments in portfolio companies, and the disproportionate administrative and financial burden of obtaining missing data.
Future approach
The Manager currently has no adopted intention to start considering the adverse impacts of investment decisions using the indicators in Table 1 of Annex I to Commission Delegated Regulation (EU) 2022/1288 and has therefore not set a date for their introduction. The possibility of changing this approach in the future remains open. If the Manager decides to start considering these impacts, it will disclose the change in its approach, including the commencement date, by updating these disclosures.
04 / SFDR
Transparency of remuneration policies in relation to the integration of sustainability risks
Article 5(1) SFDR
The remuneration policy is designed to be consistent with applicable legislation, internal rules, the business strategy and the long-term interests of the Fund and its investors. It supports sound and effective risk management and prudent management of the Fund. The remuneration structure is conservative and does not encourage inappropriate or excessive risk-taking, including sustainability risks. At the same time, it does not discourage risk-taking that is consistent with the Fund’s investment profile.
The remuneration policy is consistent with the individual assessment of sustainability risks described above. This consistency rests on the principle that not encouraging inappropriate or excessive risk-taking also applies to sustainability risks assessed in investment decision-making. The policy does not include specific ESG criteria or a link to the achievement of particular ESG targets. The absence of specific ESG criteria does not alter these principles of prudent risk management.
The Manager’s key personnel are among its founders and owners and are therefore directly motivated by the successful operation and prosperity of the Fund.
05 / SFDR
Responsibility, review and updating of information
The Manager’s statutory governing body is responsible for implementing, complying with and reviewing the policy.
The policy is reviewed at least annually or following a significant change in legislation or the Fund’s investment strategy. The Manager continuously monitors developments in sustainability legislation and regulatory guidance. If its approach or investment strategy changes, it ensures that the approach is reassessed and the policy is appropriately updated.
The Manager publishes these disclosures in a dedicated sustainability (SFDR) section of its website, accessible to investors and the public. It keeps the information up to date and publishes changes without delay, together with the date and an explanation of the changes on the same webpage. For information under Articles 3 and 5, it follows Article 12(1) SFDR; for information under Article 4, it follows that Article and the relevant provisions of Commission Delegated Regulation (EU) 2022/1288. The website states the date of first publication and the date of the most recent update.
Document date: 9 September 2026.
06 / SFDR
Legal framework
Regulation (EU) 2019/2088 (SFDR)
Commission Delegated Regulation (EU) 2022/1288