Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on the disclosure of information related to sustainable development in the financial services sector (“SFDR“) requires Alternative Investment Company Managers to disclose information related to sustainable investment policies, including information on the manner in which sustainable investment policies are implemented or not implemented.

ESG policies (E – environment, S – society, G – corporate governance) address an integrated approach to investment, taking into account environmental, social and good governance practices. From ASI’s investment perspective, ESG considers factors such as sustainability, investment risk, investor values, reputation and investment legitimacy, among others.

In summary, according to the so-called Green Deal, the implementation of ESG policies in Alternative Investment Companies is expected to contribute to sustainable development, minimize investment risks, and serve to attract investors and build a positive reputation.

In view of the completion of the investment stage, ZASI, with the adoption of the investment policy, implements the following principles for sustainable development.


By sustainability risk is meant situations or environmental, social or governance conditions that, if they occur, could have, actual or potential, a significant negative impact on the value of investments made by ASI participants.

ZASI declares that within the framework of its activities (management of ASI), it has not adopted strategies involving the consideration of risks to sustainability, and therefore – in its current activities, it does not consider these risks. ZASI has not drawn up strategies at the level of its organization defining a methodology for taking into account environmental, social or governance conditions that, if they occur, could have, actual or potential, a significant negative impact on the value of investments.

Accordingly, ZASI does not include sustainability risks in the compensation structure of those responsible for ZASI’s operations, including no policy to reduce incentives for excessive investment risk in terms of including sustainability risks.

ZASI does not rule out introducing strategies to address sustainability risks in the future.


The main adverse effects of investment decisions are the effects of investment decisions that adversely affect sustainability factors, i.e., environmental, social and labor issues, human rights issues, and anti-corruption and anti-bribery issues, and to which Article 4 and Article 7 of the SFDR apply.

ZASI declares that in making investment decisions it does not consider the analysis of adverse effects of its investment decisions on sustainability factors due to the fact that in the investment profile of ASI the assessment of sustainability factors is difficult or impossible, due to:

  1. Investing in assets that are not assessed from an ESG perspective
  2. Investing in early-stage companies – those without well-established management practices or without a declared business strategy vis-à-vis environmental or social factors
  3. short-term investment horizons of ASI deposits, so that it is difficult to verify investment objects for adverse effects on sustainability factors
  4. diversification of the investment portfolio, so that the analysis of each asset in terms of its impact on sustainability can be difficult
  5. ASI’s investment deposits are based in significant part on non-public companies that do not provide transparency on ESG practices
  6. Investments in developing entities that do not have an established history or ESG data, making it difficult to assess their sustainability impact
  7. The fact that taking ESG criteria into account does not significantly improve investment performance

As the regulation and practice of sustainability-related disclosures in the financial services industry develops, industry standards for considering the adverse effects of investment decisions on sustainability factors are developed, and as the availability of sustainability data from potential investee companies increases, ZASI may include analysis of the adverse effects of investment decisions on sustainability in its strategy.

ZASI’s ASI-managed investments do not promote environmental and social aspects or make sustainable investments. ZASI-managed investments do not take into account EU criteria for environmentally sustainable economic activities.