Pre-contractual disclosures to Investors
in accordance with
Articles 4 and 6 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27
November 2019 on sustainability-related disclosures in the financial sector (the “SFDR”).
SMOK Ventures II Coöperatief U.A. (the “Fund”) qualifies as an alternative investment fund (an
“AIF”) within the meaning of the Directive 2011/61/EU of the European Parliament and of the
Council of 8 June 2011 on Alternative Investment Fund Managers, and is managed by SMOK
Ventures Partners B.V. (the “Fund Manager”). The Fund Manager is exempt from the license
requirement of Article 2:65 of the Dutch Act on Financial Supervision (Wet op het financieel toezicht)
(“AFS”) under the so-called small managers regime of Article 2:66a AFS. Under the small managers
regime, the Fund Manager is required to submit a registration form with the Netherlands Financial
Markets Authority (Autoriteit Financiële Markten) (“AFM”), which registration form the Fund
Manager has filed with the AFM.
As clarified by the European Commission in its Q&As on sustainability-related disclosures published
on 14 July 2021, the Fund Manager must comply with certain SFDR disclosure requirements
applicable to registered AIFMs.
Definitions in the context of mandatory disclosures
A “sustainable investment” is defined as an investment in an economic activity that contributes to an
environmental objective, as measured, for example, by key resource efficiency indicators on the use
of energy, renewable energy, raw materials, water and land, on the production of waste, and
greenhouse gas emissions, or on its impact on biodiversity and the circular economy, or an
investment in an economic activity that contributes to a social objective, in particular an investment
that contributes to tackling inequality or that fosters social cohesion, social integration and labor
relations, or an investment in human capital or economically or socially disadvantaged communities,
provided that such investments do not significantly harm any of those objectives and that the
investee companies follow good governance practices, in particular with respect to sound
management structures, employee relations, remuneration of staff and tax compliance.
‘Sustainability risk’ means an environmental, social or governance event or condition that, if it
occurs, could cause an actual or a potential material negative impact on the value of the investment
‘Sustainability factors’ mean environmental, social and employee matters, respect for human rights,
anti‐corruption and anti‐bribery matters.
Categorization of the Fund
The Fund qualifies as a financial product subject to Article 6 of SFDR (the “Categorization under
Article 6”) since it does not follow any of the strategies promoting environmental or social
characteristics (Article 8 of SFDR) and does not have sustainable investment as its objective (Article 9
Unless defined herein, the capitalized terms shall have the meaning ascribed to them in the fund
membership agreement of the Fund as amended from time to time (the “Membership
Transparency of the integration of sustainable risks
In accordance with Article 6 of SFDR, the Fund Manager herewith provides information with regard
to (a) the way sustainability risks are integrated into investment decisions; and (b) the results of the
assessment of the likely impacts of sustainability risks on the returns of the financial products it
After having made a sustainability risk assessment, the Fund Manager has concluded that
sustainability risks are not relevant for this financial product, and will therefore not be integrated as
part of its decision-making processes with respect to the portfolio investments to be made by the
Fund, notably in view of the investment strategy and restrictions applicable to the Fund as further
detailed in the Membership Agreement.
Furthermore, sustainability risks will not likely have a materially adverse effect on the Fund’s
returns. Investors should however note that it may be difficult to assess with any reasonable
certainty whether sustainability risk exists, or the likely outcome of any sustainability risk on the
Adverse impacts of investment decisions on sustainability factors
The Fund does not consider the adverse impacts of investment decisions on sustainability factors in
the manner prescribed by Article 4 of the SFDR. Given the relatively small size of the organization of
the Fund Manager, such consideration and the administrative burden in connection therewith would
not be proportional.
Declaration regarding the Fund and sustainability
The investments underlying the remaining portion of this financial product do not take into account
the EU criteria for environmentally sustainable economic activities.