Transparency and disclosure under Regulation (EU) 2019/2088 on sustainability - related disclosures in the financial services sector ("SFDR")
Maniv Mobility Management Ltd (“Maniv Mobility”) makes the following disclosures in accordance with the Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (“SFDR”).
Sustainability risks policies statement
A sustainability risk means "an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment". In the context of Maniv Mobility, sustainability risks are risks which, if they were to crystallize, would cause a material negative impact on the value of the Maniv Mobility’s investment.
Integration of sustainability risks in investment processes
Consideration of sustainability risks is part of the investment decision‐making and risk management processes of Maniv Mobility relating to the funds it manages and investments it makes. Before any investment decisions are made on behalf of any funds that Maniv Mobility manages, Maniv Mobility (or its delegated portfolio manager) will identify the material risks associated with each such proposed investment; these will include any relevant and material sustainability risks. These risks form part of the overall investment proposal submitted to the investment committee. The investment committee will assess the identified risks alongside other relevant factors set out in the proposal and will approve or decline the investment proposal. The assessment of sustainability risks is done by engaging external and internal subject matter experts and is based on both private information gathered from the company management and from publicly available information. Where material issues are identified, the investment committee may request further action to be taken to ensure that these issues are properly investigated, before proceeding to investment. The potential investment may be rejected if the material issues identified cannot be mitigated. The deal team will document all material sustainability risks identified, in order to ensure appropriate monitoring, and where appropriate, value creation, of the portfolio companies’ ESG performance during our ownership period. The investment decision-making process is part of Maniv Mobility’s wider policies and procedures on the integration of sustainability and ESG risks in its decision-making process in relation to its funds generally. Further information on this is set out in Maniv Mobility’s ESG Policy available on the website.
No consideration of sustainability adverse impacts
Maniv Mobility will consider ESG factors as part of the fund’s investment process but, at this stage, will not consider adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (SFDR). Maniv Mobility has elected not to do so at the present time as it considers its existing ESG policies and procedures to be appropriate, proportional and tailored to the investment strategies of its fund, particularly given the size and the nascent nature of the fund management business of Maniv Mobility. We will continue to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance. As soon as we start considering adverse sustainability impacts of our investment decisions on sustainability factors, we shall disclose the relevant information to investors and on our website.
Article 10(1) Disclosures
Maniv Mobility Fund III (“Fund III”) makes the following disclosures in accordance with Article 10(1) of SFDR. For the purposes of Article 8(1) of SFDR, Fund III considers that it is a financial product which promotes, among other characteristics, environmental characteristics.
While Fund III does not have sustainable investment as its objective, the relevant characteristics promoted by the fund consist of climate action and green cities; and responsible consumption.
No sustainable investment objective
This financial product promotes environmental or social characteristics, but does not have as its objective a sustainable investment.
Fund III’s investment strategy involves investing in seed-stage and early-stage companies; typical investment region: global; typical sector: transportation and mobility sector.
Proportion of Investment
Currently, Maniv Mobility anticipates that at least 70% of the investments in Fund III will promote environmental or social characteristics.
Monitoring of environmental or social characteristics
During the annual ESG review, Maniv Mobility will support the portfolio companies, where possible, to gather and report on ESG metrics and indicators.
How the Environmental Characteristics Are Met
Maniv Mobility continuously monitors the characteristics of the fund and its portfolio companies. Portfolio companies report on the agreed metrics to the fund’s general partner, which aggregates and reports onward to the fund’s limited partners. Fund III expects the companies it invests in to be genuinely focused on giving back to all its stake holders including its employees, customers, suppliers, shareholders, the environment and the wider world at large. For us, ESG is not just part of a screening process. We take an active interest in how the portfolio companies manage sustainability risks and actively encourage, support and stretch them to strive for the best ESG standards practicable for their sector, business model and stage of development.
Fund III aims to make investments in companies which follow good governance practices including requiring compliance with anti-bribery and anti-corruption regulations, practicing non-discrimination policies, maintaining highest codes of ethics and business conduct, and complying with data privacy and protection (including making users aware of information collected, length of time it is preserved, how it’s used, and whether and how it is shared with other entities). In cases where the above does not exist, then Maniv Mobility will endeavor to help the portfolio companies, where practical to do so, to build these. The good governance practices of investee companies are assessed prior to making an investment as well as periodically thereafter.
Methodologies Used to Assess, Measure and Monitor the Environmental Characteristics
The environmental characteristics described above will be assessed, measured and monitored throughout the investment decision-making process and investment and divestment lifecycle of the fund. To assess, measure and monitor the environmental characteristics of the fund, an ESG diagnostic will be sent to each portfolio company, at minimum annually, to collect and assess data on detailed metrics which fall within the broad themes of climate action and green cities; and responsible consumption.
Data sources and processing
The ESG materiality assessments and ESG due diligences are carried out by Maniv Mobility deal teams and if ESG considerations are considered material, an external ESG consultant, where needed, in collaboration with the portfolio companies.
Limitations to methodologies and data
Limitations to the methodologies and data referred to in the above sections include, but are not limited to (i) limited capacity to measure or report from the portfolio companies; (ii) different reporting periods and group perimeters; and (iii) human error in the provision of data.
Maniv Mobility’s due diligence process allows for the formal assessment of potential investments on ESG matters. In order to assess the ESG risks and opportunities of each potential investment, the deal team evaluating the opportunity will be required to complete an ESG assessment check-list. This check-list consists of a standardized set of questions, across environmental, social and governance themes. In addition, since each potential investment is different in its sector, business model and execution, the deal team may add additional ESG criteria to the check-list. We may instruct external experts to perform additional ESG due diligence. Where material issues are identified, the investment committee may request further action to be taken to ensure that these issues are properly investigated, before proceeding to investment. Following the initial due diligence an annual due diligence review/assessment is performed.
Maniv Mobility’s deal teams will proactively engage with the portfolio companies to help them deliver high levels of sustainable performance. We will send an annual ESG survey to all portfolio companies to report on Maniv Mobility’s chosen ESG metrics, which will require them to share with us key information pertaining to the ESG metrics identified.
Designated reference benchmark
Maniv Mobility Fund III has not subscribed to a relevant designated reference benchmark as we are not aware of any relevant benchmarks available for our strategy. We will keep evaluating this on an annual basis.
Integrating ESG within our remuneration framework
All of the Maniv Mobility’s Partners and staff are subject to Maniv Mobility’s remuneration guidelines. The remuneration guidelines have been designed to support and safeguard Maniv Mobility’s objectives related to fund financial performance, ESG and sustainability, and ultimately the objective of delivering long-term value to its funds’ LPs, amongst a broader stakeholder group, including colleagues, peers in the industry, and the globe. The policy is designed to attract, retain and motivate talent and ensure that the interests of the employees are aligned with those of the relevant stakeholders. The remuneration policy provides a framework and guidance in relation to the total remuneration package, which consists of the following key elements: (1) fixed salary, (2) variable compensation (bonus), (3) carried interest and management company shares, (4) pension, and (5) other non-monetary benefits. The composition of each employee's total remuneration package will be based on the employee's position, responsibilities, capabilities and achievements. A number of factors are taken into account in setting remuneration levels, and these include the fund and GP’s financial performance during the compensation period, staff’s contribution to the achievement of firm’s and funds’ objectives, both strategic and operational, staff’s efforts and achievements to pursue firm’s policy on ESG in their work, investment-related or otherwise, and other considerations such as adherence to risk management and compliance with internal and external rules, management and leadership capabilities. By nature, a number of these factors are qualitative, and based on internal and external feedback for each Partner or employee. As such, currently no set mathematical formulas are established and no fixed benchmarks are used in determining individual annual remuneration level, although the component parts of the decision-making are as determined herein.
Maniv Mobility sustainability officer
For more information, please contact Jake Wieseneck (Jake@maniv.com)