This document contains:

1.     General disclaimer

2.     Privacy notice

3.     Mandatory disclosures on the basis of the EU SFDR

1.     General disclaimer

The information contained on this website (hereinafter the “Information”) is provided “as is” and has been compiled by Ardent Equity Management B.V. as accurate as possible. The Information is made available without responsibility on the part of Ardent Equity who neither assumes nor accepts any responsibility or liability (including for negligence) in relation thereto.

The Information contained or referred to may change or be updated without notice. Use of the Information is at the sole risk of the user. The Information (i) does not constitute an offer to sell or a solicitation of an offer to buy an interest in any fund managed by Ardent Equity; (ii) is not, and under no circumstances is it to be construed as a prospectus; and (iii) is not intended for distribution to or use by any person or entity in any jurisdiction or country where such distribution would be contrary to local law or regulation.

2.     Privacy notice

 Ardent Equity Management B.V. is a limited liability company established under the laws of the Netherlands, registered with the AFM and the Dutch trade register at the Chamber of Commerce under number 87410702, hereinafter “Ardent Equity” or “we”.

This privacy notice is applicable to visitors to our website or people who notify under the General Data Protection Regulation.

Visitors to our website

We anonymously measure the use of our website with the help of non-essential cookies to find out the number of visitors to the various parts of the site and/or the quality of the site.

We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website, nor do we follow any surfing behaviour on (other) websites.

Cookies are simple text files that are stored on your computer or mobile device by websites that you visit. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. We only use so-called third-party cookies, namely the cookies of Google analytics, with the following name:

_ga

_gat

_gid

The purpose of these cookies is to record if a user has accepted the use of cookies on our website. To withdraw your consent, you can adjust your browser’s settings. Find out to delete cookies at http://www.aboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit: http://tools.google.com/dlpage/gaoptout.

This privacy notice concerns only our website and does not concern any website to which our website may link. Visitors who choose to visit these third-party websites, are advised to review their privacy policies to understand the policy and practices that are related to these third-party websites.

General Data Protection Regulation

We comply with applicable laws and regulation, such as the National privacy legislation and the General Data Protection Regulation of the EU.

Our business focuses on legal entities.

We only collect personal information for the following purposes of the following persons:

• Human Resources Management: details of individuals who apply to work at Ardent Equity. We will only use the information they supply to us to process their application. We only disclose information to third parties, for example to take up a reference, when we obtained consent of the relevant individual and we will not disclose any information or take up any reference without informing them and without consent, unless the disclosure is required by law;
• To execute employment agreements: details of employees as prescribed by law;
• Business relation management/CRM: details of legal representatives of legal entities with whom we are engaged in business, details of contact persons;
• To fulfil legal obligations: details of UBO’s and legal representatives, details of employees for tax obligations; For responding to queries and providing relevant information.

The legal ground for our processing activities is:

• Execution of agreements;
• Our legitimate interest to communicate with business relations, to provide fund management, and to be able to operate as AFM-licensed financial institution.

The following personal information is collected:

• Name, address, postal code, city, country;
• Other contact details such as telephone and email address;
• Necessary screening and employment information such as Resume, Copy ID, certificates, background checks;
• KYC details such as Verified copy ID, UBO details as required by law.

Personal information that is collected is adequate, relevant and limited to what is necessary in relation to the purposes. Personal information will be destroyed or deleted if no longer necessary.

We may use third parties for certain services that need the processing of personal information such as payroll processor, IT providers and parties required for compliance reasons such as depositary offices and providers of software for CRM, AML-check and deal filing reasons.

We implemented the necessary administrative, technical and organisational measures to ensure a level of security, which is appropriate for the specific risks that we identified. Measures that we took are physical access control, logical access control, authorization levels and user records.

The persons of whom we collect personal information have certain rights:

• The right to information and access their personal information: We can be requested more information about our processing activities;
• The right to ask for rectification or deletion of personal information: When requested, we will complete or change inaccurate or incomplete data. If processing of personal information is unlawfully, we can be requested to delete personal information. For compliance reasons Ardent Equity may refuse the deletion of personal information such as but not limited to compliance with tax and AML legislation;
• The right to ask for a copy of personal information that is processed by us;
• The right to object or to complain about the collection, processing and storage of personal information. Complaints can be filed to us or to the Dutch Data Protection Authority.

3.     Ardent Equity Management mandatory disclosures on the basis of the EU Sustainability Finance Disclosure Regulation (EU) 2019/2088 (‘SFDR’).

Article 3 of the SFDR requires: “Financial market participants shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process.”

Ardent Equity Management is a single strategy investment manager that adopts an overall investment decision making and approval process for the funds it actively manages. Before any investment decisions are made on behalf of a fund it manages, Ardent Equity Management follows an investment process consisting of various phases, namely a preliminary investment sourcing/screening phase (‘Pre-Screening’), a due diligence phase (“Due Diligence”), a final investment proposal and approval phase (“Final Approval”). During the Pre-Screening phase high importance ESG risks are assessed and reported (e.g., exclusion list activities and sectors). During the Due Diligence phase, a review of legal, tax, financial and ESG risks are made. The scope of any ESG Due Diligence will be considered and, where relevant, amended to include the elements that are material to the target company’s business activities. In the Final Approval phase, the investment team will also highlight any material ESG risks that were identified during the Due Diligence phase. The Investment Committee is responsible for final investment decision-making based on a fund’s investment strategy and objectives and will in this context decide how or whether to accept ESG risks identified and how to monitor associated risks during the term of the relevant fund’s investment and divestment term. Further detail is provided in Ardent Equity Management’s Investment Policy which can be found [link].  

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.”

Article 4 of the SFDR requires financial market participants to provide transparency of adverse sustainability impacts at portfolio entity level.

Ardent Equity Management, in a manner proportionate to its size, the nature and scale of its activities and the nature of its investment strategy, considers the principal adverse sustainability impacts of investment decisions on sustainability factors as defined under and in accordance with the SFDR. This because of its limited organizational size and that it is not currently in a position to obtain from portfolio companies and/or measure all the data which it would be required by the SFDR to report on, or to do so systematically, consistently and at a reasonable cost with respect to its investment strategies to its investors and as a result  of the fact that investments at portfolio entity level are not generally required to report by reference to the same data. In addition, the final regulatory technical standards forming part of the SFDR, which also set out the scope of principal adverse sustainability impacts and the corresponding mandatory reporting template only became effective in 2023, and hence there remains uncertainty as to the practical and legal implementation of such technical standards. Notwithstanding the aforementioned, Ardent Equity Management will use its reasonable best efforts to monitor its portfolio companies’ ESG performance on a quarterly basis and report thereon periodically as set out in the ESG Policy. Also, when making investment decisions for the fund it manages, Ardent Equity Management seeks to take into account principal adverse impacts of investment decisions on sustainability factors. Every investment opportunity reviewed will be subject to an ESG analysis to determine the most material ESG themes and risks. These themes consider principal adverse impacts.

Article 5 SFDR requires financial market participants to provide transparency of remuneration policies in relation to the integration of sustainability risks.

Ardent Equity Management is registered as a ‘light’ manager in terms of the Alternative Investment Fund Managers Directive (‘AIFMD’) and is as a consequence not required to prepare a remuneration policy as described in the AIFMD. Ardent Equity Management pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus and/or carry). Variable remuneration for qualifying staff considers, among other factors, compliance with internal policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process and does not contain any incentives that could lead to sustainability risks being disregarded when making investment decisions and monitoring such investments made.

Article 10 SFDR requires financial market participants to provide transparency of environmental or social characteristics and of sustainable investments

1. The fund managed by Ardent Equity Management will endeavour to promote, among others, the following environmental or social characteristics:

• It will exclude investments that are exposed to unmanageable principle adverse impacts;
• It will exclude investments in accordance with its exclusions policy
• It supports its portfolio investments in improving their ESG performance through an annual ESG review cycle and through continuous engagement;
• The fund will seek to promote knowledge sharing and exchange of best practices on ESG related topics across its portfolio;
• It strives to commit to the UN Principles for Responsible Investment (UN PRI), including by way of: i )incorporating ESG issues into the investment analysis and decision-making processes, ii) seeking appropriate disclosure on ESG issues by the portfolio entities in which it invests, iii) promoting the acceptance and implementation of the UN PRI within the investment industry, iv) reporting on activities and progress towards implementing the UN PRI.

2. To measure and monitor the attainment of the environmental and social characteristics listed above, the fund uses, among others, the following sustainability indicators:

•  Principal adverse impact indicators (e.g.,  GHG emissions carbon footprint, GHG intensity, energy consumption intensity per high impact climate sector, emissions to water etc.)
• ESG risk evaluation (internal qualitative and/or quantitative assessment overseen by Fund’s investment manager’s Investment Committee)
• ESG performance evaluation (internal qualitative and/or quantitative assessment overseen by the Fund ’s investment manager’s Investment Committee)
• Assessment of portfolio companies with regards their good governance practises

3. The fund will endeavour to disclose in its pre-contractual disclosures to investors such information required in terms of Article 6(1) SFDR.

4. The fund will to the best of its ability, dependent on the quality and quantity of portfolio data received, include in its periodical reports a description of the items described in Article 11 SFDR (insofar relevant).