Sustainability at ALTUM

Sustainability is a key part of ALTUM’s business and strategy and has become an important strategic driver for the banking sector as well as for development finance institutions in Europe. ALTUM takes responsibility for the long-term economic, environmental and social impact of its day-to-day activities and continuously works to ensure that the investment decisions it makes in building its portfolio contribute to sustainable development, do not adversely impact sustainability factors and facilitates its clients’ transition towards a sustainable economy and encourage responsible business practices.

 

Sustainability is an integral part of ALTUM. Sustainability strategy defines goals for integration sustainability aspects into all operational areas of ALTUM, including risk management, portfolio impact development and internal operations. 

 

ALTUM commits to contribute to sustainable development and has prioritised the UN Sustainable Development Goals (UN SDGs), which are closely linked to the company operations and strategic objectives.

Impact

Materiality aspect

UN SDGs

Climate issues

Financial instruments for climate change mitigation

 

Climate resilience considered in all financing decisions

 

Raising awareness of climate change improving climate resilience

 

Impact of own daily activities on climate

  

Governance

Fair and ethical governance, anti-corruption

 

Open communication and stakeholder involvement

 

Sustainable procurement

 

Cybersecurity, right to privacy and data protection

 

Services

Promoting entrepreneurship, employment

 

Governance decisions upon all financing issues

 

Social considerations in all financing decisions

  

Working environment

Employee health and safety

 

Fair treatment of employees

 

Staff training and development

 

Diverse and inclusive working environment, gender equality

  

Society

Fostering and strengthening the entrepreneurial spirit

 

Promoting financial literacy in society

 

Improving the economic status of women

   

Materiality aspect was defined while conducting stakeholder survey for materiality matrix. 

Towards sustainable finance

We work towards sustainable finance and the integration of sustainability into all Altum processes and disclosures related to sustainability in the financial services sector 

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Work is under way to expand the range of sustainable finance instruments

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SMEs and Midcaps are promoted to move towards sustainable development through appropriate access to finance and incentives

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Overall, financial sector and public support is increased to accelerate the transition of businesses to a sustainable economy

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Internal processes are reviewed to integrate ESG considerations in financing decisions and further portfolio monitoring

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Staff competencies are developed in integrating sustainable finance and ESG considerations into risk management

 

 

Materiality matrix for sustainability

To establish ALTUM’s materiality matrix for sustainability and define the ambition level for sustainable finance in the loan portfolio, stakeholder identification, mapping and a survey were carried out at the end of 2021 to identify the material aspects to be included in the sustainability content. The survey asked for an assesment of ALTUM’s performance so far in the areas of environmental, social and corporate governance as well as expectations of ALTUM in the areas of sustainability in the business environment, day-to-day operations, community support and development, as well as ALTUM as an employer.

 

Stakeholder relations

Altum works closely with its stakeholders, and recognising Altum’s specific role in the national economy identified the needs of stakeholders and address them. Altum is aware of and assesses the social, environmental and economic impacts of its activities and involves stakeholders in solving issues of mutual concern. In building relationships with stakeholders, Altum organises and engages them in consultations, partnerships, informative and educational events.

 

Partners

ALTUM cooperates with state and non-state institutions, financial institutions, various types of international institutions and associations in developing and implementing state support programs, as well as attracting financing.

 

Public support, investment in local community development

ALTUM’s management and employees actively engage in public education activities throughout the year, focusing on various initiatives aimed at business development, promoting societal well-being, contributing to climate change mitigation efforts, and fostering long-term economic growth. 

ALTUM’s ambitions for sustainable finance are realised voluntary and are driven by:

 

  1. the expectations of stakeholders, such as investors, credit rating agencies, international lenders, Nasdaq, for Altum to be a Latvian development finance institution with a highly significant impact on the Latvian economy;
  2. eligibility requirements for public funding available from the EU Cohesion Policy and/or RRF instrument contributing to the Sustainable Europe Investment Plan/Green Deal Investment Plan, where Altum plays a critical role in the implementation of financial instruments in the SME sector in Latvia.

Taking into account the stakeholder survey conducted for development of ALTUM materiality matrix, TOP3 priorities were defined for sustainable financing:

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Improving access to sustainable financing for SMEs:

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Promoting projects that will have a positive environmental and social impact;

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Expanding the sustainable set of financial instruments.

The ambition level of Altum is also influenced by the sustainable financing framework already in place for part of Altum’s portfolio

  • e.g., the portfolio financed under the Altum Green Bond Financing Framework 2021, taking into account the Green and Social Bond Principles published by the International Capital Market Association (ICMA)).
  • Although not binding on Altum, the Company follows the practices of the international financial institutions sector in its day-to-day operations. Thus, the EBA (European Banking Authority) guidelines on the integration of ESG considerations in credit risk management, including lending and monitoring, are reviewed alongside with assessing their further integration into Altum’s credit risk management processes, both when making financing decisions and improving Altum’s internal processes.

 

 

ESG roadmap 

In September 2021 ALTUM became the first organisation from Latvia to join Nasdaq Sustainable Bond Network. 

 

Portfolio contribution to sustainable development  

For detailed information on environmental and social impacts of ALTUM-funded projects (see corporate governance report 2022, page 12-13).

 

ALTUM-funded sustainable projects with Green Bond financing

In 2017 Altum issued bonds as series of notes quoted on Nasdaq Riga, becoming the first national development institution of a Central and Eastern European country to issue green bonds. You can find more about Green Bond framework here

Sustainable projects as per 30th of June 2023 can be found in investor’s report and project report.

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The funding attracted from issuing the Green Bonds is used to fund sustainable business projects in the fields of energy efficiency, energy generation from renewable energy resources, green buildings and sustainable transportation, including energy service companies (ESCO) servicing companies in these fields.

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As at 30 June 2022 Altum has committed a total of EUR 18.5 million and disbursed a total of EUR 17.3 million for green projects.

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At 30th of June 2024 Green Bond portfolio project contribution to sustainability has generated annual reduction of GHG emissions corresponding to 7 963 tons CO2e per year. That in turn corresponds to an actual reduction of 430 tonnes CO2e p.a. per committed 1 million EUR boosted above average by projects of Energy Efficiency.

In its day-to-day operations in implementing the state-delegated functions to foster the development of national economy and taking voluntary company responsibility for impact on society and environment, Altum acts in compliance with the organization’s strategy and values. Our values define our daily activities, are reflected in our operations and conduct, and fully permeate our positive attitude and openness to changes and innovation. Altum’s value system is designed to provide a clear perception of Altum to our external partners and clients as well as to our employees.

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Team

We work professionally in a unified team together with our customers and partners, thereby creating and implementing effective state aid programmes that are relevant to our client's needs

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Excellence

Making use of our experience and creative perspective, we strive for excellence in everything we do. We constantly develop ourselves. We take on the complicated, yet finish with simplicity. We look at things and challenges creatively

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Resposibility

We strive to reach our goals, pursue everyday work with efficiency, fairness and respect

ALTUM Strategy 2022-2024

Following strategic development directions and long-term objectives are set in the approved JSC Development Finance Institution Altum Strategy for the period 2022 – 2024.

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The main non-financial objective is to support and facilitate availability of finances to business and to contribute to national economic development.

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The main financial objective in implementing the state support programmes is to ensure positive return on Altum’s equity.

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Priority areas include:

  • issuing and servicing guarantees and loans
  • venture capital investments
  • solutions for climate change mitigation including implementation of energy efficiency programmes in both the residential building and corporate segment,
  • initiation of new projects by expanding the range of the financial instruments offered
  • development of the Latvian Land Fund
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The main target activities embrace support for entrepreneurs, farmers and certain categories of persons; energy efficiency; the management of the Latvian Land Fund

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Altum will particularly focus on environmental, social and corporate governance (ESG) considerations, both in financing decisions and in Altum's internal processes.

Notable achievements and awards

Long-term credit rating Baa1

3rd place in the Baltics in “Best investor relations in the bond market” nomination

Nomination “Risk  Management Strategist”

Platinum award in Sustainability index since 2021 

“Nasdaq Baltic Awards 2019” in “Stock market event of the year” nomination

Family friendly workplace

2nd place in “Fair Pay 2023” organised by Figure Baltic Advisory

Sustainability memorandums 

Altum has joined memorandums of cooperation in sustainability area. 

 

Governance structure

To ensure the achievement and sustainability of Altum’s strategic objectives, a corporate governance model was elaborated and developed. Starting with 2021, Altum applies the Corporate Governance Recommendations, incorporated in the Code.

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Shareholders’ representatives

 

Effective involvement of shareholders in decision-making helps to achieve the company’s financial and non-financial objectives and ensures its sustainability.

State Secretary of

the Ministry of Finance

 

Baiba Bāne

State Secretary of

the Ministry of Economics

 

Edmunds Valantis

State Secretary of

the Ministry of Agriculture

 

Raivis Kronbergs

Supervisory Board

 

The members of Altum Supervisory Board have relevant experience and expertise, and possess a range of skills and knowledge, including in the financial sector, business development management as well as corporate strategy and financial management. The Supervisory Board is gender-balanced and respects the principles of diversity.

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Līga Kļaviņa

 

Chairperson of the Supervisory Board

 

Deputy State Secretary for Financial Policy at the Ministry of Finance of the Republic of Latvia. Prior to that, she held several senior positions in the Ministry of Finance, representing the interests of the Latvian State in state-owned companies as well as working for a long time in international financial institutions.

 

Holder of a Master’s degree in Law from the Institute of International Affairs, University of Latvia.

 

Term of office: 26.12.2025

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Krišjānis Znotiņš

 

Member of the Supervisory Board

 

15+ years experience in the management and corporate governance working in executive positions in financial sector companies (DNB leasing, Eleving Group Latvia, Wandoo finance, Luminor bank).

 

Holds Bachelor’s degree from the Banku Augstskola and Master’s degree in business management in international finance and banking from SBS Swiss Business School (Switzerland).

 

Term of office: 30.04.2027

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Ansis Grasmanis

 

Member of the Supervisory Board

 

20+ years experience in the management and corporate governance and 10+ years experience in risk management and internal control, working in top management positions in financial sector companies (SEB bank, Swedbank), has held top positions as Chairman of the Board of Directors at Banka per Biznes (Kosovo) as the EBRD’s nominated member of the Board of Directors, member of the Supervisory Board at the First Ukrainian International Bank (Ukraine), Banku Augstskola and SJSC State Real Estate.

 

Holds Master’s degree in mathematics from the University of Latvia and FCT (Association of Corporate Treasurers) and FCCA (Chartered Association of Certified accountants) qualifications.

 

Term of office: 30.04.2027

Management Board

Reinis Bērziņš

 

Chairman of the Management Board

 

Business management and finance professional with extensive experience in managing companies and institutions.

 

Holder of a Master’s degree in International Finance and Banking from BA School of Business and Finance, a Master’s degree in Business Administration from the Swiss Business School and a Master’s degree in Law from the University of Latvia.

 

Main areas of responsibility: finance and resource management, sustainability management and human resources.

 

Chairman of the Advisers’ Convention of BA School of Business and Finance. Chairman of the Supervisory Board of Riga Stradiņš University.

 

Managing Altum since 12 October 2015.

 

Term of office: 27.05.2027.

Jēkabs Krieviņš

 

Member of the Management Board

 

Financial expert with more than 25 years of experience in the organisation and management of corporate lending, gained working in both the commercial banking and public financial institutions sectors.

 

Holder of a Master’s degree in Business and Institutional Management from Riga Business School, a Certificate in Banking from BA School of Business and Finance and a Bachelor’s degree in Economics from Latvia University of Agriculture.

 

Main areas of responsibility: IT and technology development, Altum’s customer and regional service centres, private housing guarantees, oversight of the Latvian Land Fund.

 

Member of the Board of the European Association of Guarantee Institutions (AECM).

 

Term of office: 27.05.2027.

Inese Zīle

 

Member of the Management Board

 

20 years experience in the financial sector, including more than 15 years managing various departments, as well as experience in the public sector.


Holder of a Master’s degree in International Economics and Business from the University of Latvia.


Main areas of responsibility: development and implementation of Altum’s state support programmes, energy efficiency in residential buildings, corporate client services, marketing and public relations.


Altum’s representative on the Council of the Finance Latvia Association. Member of the Supervisory Board of JSC Sadales tīkls.

 

Term of office: 27.05.2027.

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Ieva Jansone-Buka

 

Member of the Management Board

 

Experience in the financial sector, working in senior positions in both commercial and corporate banking.


Holder of a Professional Master’s degree in business from the Stockholm School of Economics in Riga, a Bachelor’s degree in Management and Political Science from the University of Latvia.


Main areas of responsibility: venture capital financial instruments, organisation and management of the lending process, export guarantees, implementation of the social entrepreneurship and energy efficiency programmes.


Member of the Supervisory board of SIA Tet.

 

Term of office: 17.03.2027.

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Juris Jansons

 

Member of the Supervisory Board


More than 20 years of experience in operational compliance, financial crime prevention and risk management, gained in senior positions in the commercial banking sector.


A Master’s degree in Law from the University of Latvia. In addition to many years of experience in the field of anti-money laundering, a CAMS certificate obtained.

 

Main areas of responsibility: risk management, anti-money laundering and countering the financing of terrorism and proliferation, compliance and monitoring of client liabilities, legal and administrative management.

 

 

Term of office: 08.01.2026.

ALTUM committees

 

The committees of Altum have been established by decision of the Management Board of ALTUM and their primary tasks, rights and responsibilities, operational principles as well as rights and obligations of the members of committees are outlined in the committee regulations.

Audit Committee

 

Since 1st of December 2017, Altum has an Audit Committee; among other things, it monitors the effectiveness of the internal control and risk management to the extent it relates to financial reporting and impartiality. The Audit Committee monitors Altum’s financial reporting process and performs other duties as required by the Financial Instrument Market Law. The Audit Committee worked closely with the Internal Audit Division on the audits.

Gunta Darkevica

 

Head of the Audit Committee. Sworn auditor.

 

Longstanding experience with audit related fields. Fellow Member of UK Association of Chartered Certified Accountants (FCCA), Certified Internal Auditor (CIA) of the international Institute of Internal Auditors, Member of the Latvian Tax Consultants Association, certified tax consultant.

 

Obtained social sciences master’s degree in management science at the University of Latvia.

 

Term of office: 02.01.2025.

Ilze Baltābola

 

Member of the Audit Committee.

 

Deputy director of the Economics Ministry’s Department of Entrepreneurship Competitiveness.

 

She has a Master’s Degree in European Studies from the Faculty of Business Management and Economics of the University of Latvia.

 

Term of office: 02.01.2025.

Nils Sakss

 

Member of the Audit Committee.

 

Fiscal Policy Department director at the Ministry of Finance.

 

Prior to that, he worked as an expert in Ukraine, Croatia, Hungary, Libya and Slovenia, served as the director of the secretariat of the Education Innovation Fund and Society Integration Fund, director of the Strategic Planning Department and the European Integration and International Aid Coordination Department of the Ministry of Education and Science, as well as the Cultural, Education and Science Attaché at the Latvian Mission to the EU. Worked as a lecturer at the University of Latvia and was the council chairman of joint-stock company Latvijas Loto.

 

Holds a master’s degree in physics and economics from the University of Latvia.

 

Term of office: 02.01.2025.

Internal audit 

The Internal Audit Division, an independent body subordinated to Altum Supervisory Board, monitors Altum’s internal control system and assesses its adequacy and efficiency. The Head of the Internal Audit Division is appointed by a decision of Altum’s shareholders’ meeting.

Roberts Jansons

Head of Internal Audit Division

More than 15 years of leadership experience in conducting internal and financial audits related to implementation of programs financed by European Union funds and other foreign financial instruments. Gained international experience in leading the Audit authority (ESF programme) in Finland.

Obtained professional bachelor’s degree in finance in The Walker School of Business, Mercyhurst University (PA, USA) and MBA in International Finance and Banking in BA School of Business and Finance (Riga, Latvia) developed jointly with SBS Swiss Business School (Zurich, Switzerland)

 

 

Objectives

The objective of the Internal Audit Division is to strengthen Altum’s values and to help the Supervisory Board, Management Board and heads of business units to achieve their strategic and business objectives more effectively through independent and impartial assessment. Every year the shareholders’ meeting approves the annual action plan of the Internal Audit Division, about the implementation of which the Internal Audit Division reports to the shareholders’ meeting. The Supervisory Board supervises the Management Board in ensuring that the internal control system is established and operates effectively

 

Operation

  • The Internal Audit Division performs its functions in accordance with the applicable laws and regulations, international standards for the professional practice of internal auditing, and Altum’s internal regulations.
  • The Internal Audit Division prepares and submits to the shareholders’ meeting, at least once a year, a report on the audits performed, the main problems and drawbacks identified, assessing the effectiveness of the internal control system and giving an opinion on the measures to be taken to improve the functioning of the internal control system.

Corporate governance report

The Corporate Governance Report 2022 is prepared in accordance with the requirements of Article 56(2)(3) of the Financial Instrument Market Law and based on the good corporate governance recommendations for capital companies in Latvia Corporate Governance Code (January 2021) (hereinafter – the Code) developed by the Corporate Governance Advisory Council. The recommendations were developed taking into consideration the requirements for companies provided in the legislation of the Republic of Latvia as well as corporate governance recommendations of the Organization for Economic Co-operation and Development. Besides, the Corporate Governance Report covers environmental, social and corporate governance (hereinafter – ESG) considerations based on the Nasdaq ESG Reporting Guide 2.0 (May 2019).


Previous reports available in the following links: 

 

Corporate governance report is a part of audited annual report

Risk management

Risk management aims to identify, assess, manage and control potential events and situations to provide assurance that the strategic objectives of the business are achieved.

 

Altum has a risk management framework, taking into account the Company size, structure and operational specificities as well as the limited capacity to manage individual risks. Altum manages risks affecting its operations in accordance with the Company approved internal regulations for risk management, which describe and define the measures used to manage risks inherent in its operations.

 

The following are the major risk management principles adhered to:

  • risk management is part of day-to-day functions;
  • Altum identifies and assesses potential risks before introducing new products or services;
  • while assuming risks, Altum maintains its long-term capacity to meet its objectives and targets;
  • Altum does not engage in transactions, activities, etc., which create risks that threaten the stability of its business or which may significantly harm its reputation.

 

Altum uses various risk analysis methods and tools to manage its risks, and sets risk limits and restrictions.

Altum runs a continuous environmental management and operational improvement cycle, including the revision of its long-term and short-term environmental targets to find a balance between efficiency of business operations and their impact on the environment and quality of life.

Altum is aware of its impact on climate change, as well as the impact of climate change on Altum’s operations. Altum’s environmental policy defines its objectives and commitment to conduct its activities with the least possible negative impact on the environment, both directly and indirectly.

 

Transition risk analysis 

 

Transition risk substantially impacts the economic activities of the companies with further direct effect on ALTUM by the companies’ debt service capacity or maintenance of the market value of the collateral. Transition risk might  directly or indirectly occur by customers transition to low carbon economy. The transition risk might increase, for example, by new climate and environment regulatory requirements on reduction of GHG emissions or technological progress of competitors. Transition risk can also be heightened by behavioural change of the market or customers, which depends on the customer’s capacity to bear the investment costs of transition project and its timely realisation.

 

Table 1: Transition risk heatmap – high and very high transition risk exposure in individual economic sectors as at period-end 

*Total credit exposure: gross credit portfolio and loan commitments

Altum CO2 footprint

 

In 2023, the total emissions (Scope 1 and Scope 2) amounted to 89 tCO2e, (2022:  99 tCO2e ), representing a decrease of 58.6% compared to 2018 (216 tCO2e). Compared to 2022, there has been a 10% reduction in scope 1 and scope 2 emissions:

fuel

diesel

Total:

28 tCO2e

0.7 tCO2e

29 tCO2e

electricity

heat

Total:

18 tCO2e

43 tCO2e

61 tCO2e

In order to achieve its intention for reduction of GHG emissions, an energy audit of the Company was also carried out in 2018, covering the analyses of natural gas, car fleet and electricity consumption and possible activities to improve energy efficiency. Based on the conclusions and recommendations of the energy audit, Altum annually implements targeted activities to increase the Company’s energy efficiency: work is underway to improve the energy efficiency of operations and buildings, reduce business travel through remote meetings, teleworking and the transition to an energy-efficient car fleet for the company needs. Special emphasis is placed on educating employees, encouraging a change in their attitudes and increasing their commitment to reducing their individual environmental impact as well.

Assessment of CO2 emission intensity:

In 2023, emission generated per employee amounted to 0.42 tCO2 (the indicator remained unchanged since 2022), which is 57% less than in 2018 (2018: 0.97 tCO2e).

In 2023, ALTUM generated 0.08 tCO2 per EUR 1 million of gross financial instrument portfolio, which is 20% less than in 2022 (2022: 0.1 tCO2 emissions per EUR 1 million of financial instrument portfolio). Since 2018, there has been an 80% reduction in emissions (2018: 0.41 tCO2 emissions per EUR 1 million of financial instrument portfolio). Since 2018, ALTUM has not only reduced emissions but also increased the size of its gross credit portfolio.

The opinion on the greenhouse gas emission volumes was prepared by ALTUM and approved by the technical expert SIA TUV NORD Baltic in February 2024.

Environmental impact actoins

Altum strives to minimise the amount of waste it produces, segregates waste, provides separate waste bins for batteries (hazardous waste) in offices, promotes recycling and reduces greenhouse gas emissions that are directly linked to Altum activities.

Key actions:

Replacement and upgrading  of the heating system in the central office  

Replacement of the car fleet, significantly reducing fuel consumption and CO2 emissions

LED lighting installed in offices, as well as motion sensors in certain areas

Waste sorting ensured

Digital document management system established

Reduced office paper consumption

Drinking water filters installed, PET bottles phased out

 Cleaning service ensured, including the use of environmentally friendly products

Continuous recycling of waste paper

Bike parking and shower facilities installed

ESG aspect management in AIF ACF

Management of ESG aspects over investment life cycle

Publication date 28.12.2022.

 

ESG Declaration

 

ACF performs investments with due care towards target company’s activities in ESG areas and expected transitional changes of the economy upon target company’s upstream and downstream value chains.

 

We identify and manage ESG issues at each different stage of the investment life cycle. Assessment of ESG aspects is fully integrated in our investment decision process already at investment proposal stage as well as further at investment monitoring stage. 

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ESG Framework

 

The Fund’s
investment framework (regulatory Directions of Cabinet of Ministers of Latvia,
LPA) provides particular mechanisms for investment proposal considering ESG
aspects. Each investment is performed in accordance with those mechanisms that
are fully integrated in the Fund’s internal processes and documents (like
Investment Memorandum).

 

Criteria for Responsible Investments

Each investment target must meet Preconditions *

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Exclusion list of industries

– sale of weapons and ammunition,

– manufacture and sale of tobacco products,

– sale of alcohol,

– gambling and betting activities,

– financial and insurance activities,

– activities with real estate,

– development of real estate (residential properties).

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Viable business model

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Investment supports the investment target's activities in line with the European Union objectives and Latvia’s obligations related to the green and digital transformation, including the European Union’s objective of achieving climate neutrality by 2050*

* according to Directions of Cabinet of Ministers of Latvia nr. 458 dtd 14 July 2020

Responsible Investment Criteria Dimensions

 

We define the following list of ESG aspects to be assessed, where applicable, for each portfolio company during investment process and monitored and followed consistently. Key ESG metrics are set and reviewed periodically based on available reliable data.

 

Instruments for assessment of ESG aspects

ACF team has developed instruments for assessment of investment target’s ESG aspects that are integrated in the Fund’s operational documents and internal processes and applied in investment process for each and every investment, as well as in further investment monitoring and divesting stages:

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ESG aspects materiality and impact model for new investments: assessment model and outcome included in Investment Memorandum, reviewed on periodic basis during investment monitoring stage (applied as of July 2021);

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Assessment of target company’s governance principles: performed in addition via Interest rate assessment model and outcome included in Investment Memorandum (applied as of July 2021);

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Preconditions set in ESG Framework – exclusion list of industries, viable business model, supports climate neutrality ambition.     

Publication date 28.12.2022.

Principal Adverse Impact Statement

Scope

This disclosure is applicable to AIF Altum Capital Fund managed by JSC Development Finance Institution ALTUM.

 

PAI statement

This disclosure is applicable to AIF Altum Capital Fund managed by JSC Development Finance Institution ALTUM.

 

The Sustainable Finance Disclosure Regulation (SFDR)[1] defines sustainability factors as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. Principal adverse impact is generally understood to mean the negative impact, caused by an investment decision, on these factors.

 

This statement describes how we consider principal adverse impacts (PAI) of our investment decisions on sustainability factors, as per Article 4 of the SFDR.

 

This statement applies as of 31 December 2022. It will be reviewed at least annually.

 

[1] Regulation EU 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector.