Sustainability-Related Disclosures

This page provides investors and stakeholders information on sustainability related matters of Incofin CVSO, as required under the regulation on sustainability-related disclosures in the financial services sector (EU/2019/2088) (hereinafter “SFDR”)

Incofin CVSO is SFDR-aligned and in line with Article 9 or “dark green” classification, having sustainable investments as an objective. As an impact fund, Incofin CVSO seeks to invest in companies that are not only financially sustainable, but also contribute to solving socio-economic problems, while avoiding harm to its end-clients, local communities, and the environment in which it invests. We have fulfilled the disclosure requirements laid out in the SFDR, as described below.

Sustainability Risk Policy

Our Sustainability Risk policy describes our approach to sustainability, including how sustainability risk assessment is integrated into the investment decision-making process under Article 3 of SFDR.

Incofin CVSO considers the sustainability risk of all investments from a double materiality perspective:

  • Inside-out: the impact of our organisation and investments on the sustainability factors in the outside world, resulting in positive and/or negative impact.
  • Outside-in: the impact of sustainability factors in the outside world on our organisation and investments, resulting in sustainability risks.

Sustainability Risk Policy


Principal Adverse Impact Statement

Incofin CVSO has opted-in to report on the Principal Adverse Impact (PAI) indicators of our portfolio companies as defined by Article 4 of SFDR, including indicators on greenhouse gas emissions, biodiversity, water emissions, waste, social violations and governance issues, for all the funds we manage and advise. In addition, Incofin CVSO will report on at least one additional environmental indicator and at least one additional social indicator as required by the regulation. The first quantitative reporting is due on June 30th, 2023 for the reference period of January 1st to December 31st, 2022.

As the Fund does not have explicit environmental objectives, some environmental-specific PAI indicators are not currently track (i.e. GHG emissions, biodiversity, water emissions, etc.). However, the social and governance PAI indicators are largely already part of our processes. To comply with the SFDR, we will start tracking all the mandatory PAI indicators.

Given the pioneering target investment sector of the Fund, availability of data is a challenge for identifying the PAI indicators. Incofin CVSO has been working with its impact investor peers through the Social Performance Task Force (SPTF), a financial inclusion network of over 4,500 members, to standardize methodologies, metrics, data collection and reporting of the PAI indicators ahead of the June 2023 deadline.

The full PAI Statement is available here.

2022 PAI Disclosure


Remuneration Policy

Our Remuneration Policy was updated to ensure consistency with our Sustainability Risk Policy as required under Article 5 of SFDR.

The Remuneration policy has been designed to ensure employees are rewarded for behaviour that upholds a culture aligned with the interests of our clients and shareholders, and specifically to encourage responsible behaviour that supports long-term sustainability, ESG and impact goals. Two key aspects of the Remuneration policy that reflects the sustainability principle are:

  • Variable components are modest relative to the fixed remuneration as to not create an adverse incentive;
  • Part of all staff’s performance-based remuneration depends on achievements of sustainability, ESG and impact goals, as set and agreed between employees and direct managers at the start of the year.


Article 9 disclosures

Incofin CVSO is classify under Article 9 of SFDR. Please see below for fund-specific disclosures.

CVSO-SFDR-website disclosures