Investment Focus / Strategy

In EOS, we believe that Small Medium Enterprises (SME’s) and MidCaps are the absolute backbone of the Greek Economy. On that front, we provide the necessary growth capital that will empower them to unleash their full potential
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We focus on healthy and strong SMEs with robust financial performance and great growth prospects. Our target companies have strong value proposition and excellent management teams, with clear competitive advantages in their sectors and solid growth plans that will allow them to expand their businesses domestically or abroad.

We work closely with existing management teams following an active management approach throughout the life of the investment by utilizing our deep knowledge of the domestic market and our local and international networks and resources. We believe in empowering strong management teams with capital and ideas, focusing on adding strategic value to our portfolio companies.

We support our portfolio companies in defining and executing upon their growth strategy. Our aim is to create an investment infrastructure that will unleash their full potential, envisioning to become the driving force for the development of healthy local entrepreneurship in Greece, simultaneously contributing to the social and economic prosperity of Greece.

As far as sectors are considered, EOS aims to aid in the expansion of sectors that will help build a new era for the Greek Economy, moving from a consumption-based to an export-based economy. Sectors such as Food and Beverage, Hospitality Services, Fintech, Industrials, Pharmaceuticals and Selectively Retail are of high interest.

Responsible Investing – ESG Policy, Sustainability criteria

EOS has developed a holistic system of Environmental, Social and Governance policies that ensure high levels of sustainability for our portfolio companies.

Our Responsible Investing Policy is implemented across all stages of the investment process as we believe that only by aligning the interests of our portfolio companies with those of society, we can enhance investors returns and at the same time, have a lasting, positive impact in the economy.

We closely monitor on a recurring basis our portfolio companies on ESG performance, as we deeply understand the materiality of ESG practices and policies. We, therefore, prefer a hands-on approach in managing and supporting them to navigate all ESG related issues while encouraging them to adhere to the highest standards of business conduct.

Disclosures on the implementation of the requirements of the Regulation (EU) 2019/2088

Overview of SFDR
The Sustainable Finance Disclosure Regulation (SFDR) imposes mandatory ESG disclosure obligations for financial markets participants.
SFDR aims to bring a level playing field for Financial Market Participants (FMP) and Financial Advisers on transparency in relation to sustainability risks, the consideration of adverse sustainability impacts in their investment processes and the provision of sustainability related information with respect to financial products. SFDR requires Asset Managers, such as AIFMs, to provide disclosures on how sustainability risks are integrated both at entity and product level.

Defining Sustainability Risks, Sustainability Factors & Principal Adverse Impacts (PAIs)
Sustainability Risks are defined as Environmental, social or governance events or conditions that could cause an actual or a potential material negative impact on the value of an investment,
Sustainability Factors are defined as Environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters,
Principal Adverse Impacts (PAIs) are defined as the impacts of investment decisions and advice that result in negative effects on sustainability factors.

SFDR Website Disclosures of EOS Capital Partners AIFM S.A.
EOS Capital Partners AIFM S.A. provides information on the following in accordance with SFDR:

EOS Hellenic Renaissance Company SCA, SICAV-RAIF (EHRF)

• Integration of sustainability risks in the AIFM’s investment decision-making process (based on Article 3 par. 1)
• PAIs (Article 4 par. 1 & 2)
• Consistency of the AIFM’s Remuneration Policy with the integration of sustainability risks (Article 5 par. 1)
• Sustainability Criteria at product level (Article 7)
• Promotion of environmental or social characteristics and of sustainable investments (Article 10)

Article 3 SFDR: Integration of sustainability risks in the AIFM’s investment decision-making process

Since its inception in 2018, EOS Capital Partners AIFM S.A. has established its Environmental & Social Assessment System (ESMS) for new financings. Within the framework of this system, the AIFM has ensured that its business activities are monitored based on any possible substantial environmental and social impact. In more detail, the AIFM has implemented Environmental & Social Risk Screening via corresponding Risk Assessments with regards to its potential investees.
Those two elements constitute part of the ESMS procedure for business activities, which is consisting of the following steps:
♦ Environmental & Social (E&S) Risk Screening: screening the investees’ company businesses based on the AIFM’s exclusion list, which is outlined in its E&S policy,
♦ Environmental & Social (E&S) Risk Assessment: determination of possible Environmental & Social (E&S) risks based on related questionnaires answered by the investees. Those questionnaires are being reviewed based on the EBRD’s E&S Categorisation List and the AIFM’s Integrity Red Flag Checklist,
♦ Environmental & Social (E&S) Risk Control: Based on the findings of the aforementioned Environmental & Social (E&S) Assessment, the AIFM decides whether to proceed with the potential investment or not,
♦ Environmental & Social (E&S) Risk Monitoring: The AIFM reviews its portfolio on a regular basis to ensure the implementation of the necessary Environmental and Social Policies during the lifecycle of each investment,
♦ Environmental & Social (E&S) Due Diligence Reporting within the framework of the AIFM’s exit investment strategy: During the exit period, the AIFM states that it provides full disclosures on Environmental and Social issues affecting the potential investee and all the measures taken by the AIFM to tackle those issues and, thus, improve the E&S performance of the aforementioned investee.

Article 4 SFDR: Principal Adverse Impacts (PAIs)

Based on its established ESMS, EOS Capital Partners AIFM S.A. has depicted a range of business activities with adverse impact to the environment. As part of its Responsible Investing and Sustainability Strategy, the AIFM will refrain from entering business with legal entities operating in any of the above-mentioned activities. For example, the AIFM will not proceed with potential investees who may be engaged in activities appearing on the EBRD’s Environmental and Social Exclusion List, as described in its ESMS.
Furthermore, in the context described above and regarding current investees, no PAIs have been identified in combination with the small size of the investees, as well as the limited scale and complexity of their activities. The AIFM holds a strong view that sustainability risks or PAIs do not in any way relate (within the context of the SFDR) to the current investments of the managed AIF. In case any change occurs, the AIFM will, within reasonable time, proceed with publishing the relevant information in its website.

Article 5 SFDR: Remuneration Policy

Within the implementation of EOS Capital Partners AIFM S.A.`s Responsible Investing Strategy and Remuneration Policy, there is no indication of any excessive sustainability risks. By way of explanation, the relevant Remuneration Policy dynamically discourages potential conflict of interest situations and focuses on fixed remuneration versus variable remuneration. In case that any extraordinary sustainability risks are identified, the AIFM will undertake, within a reasonable time, the necessary amendments to its Remuneration Policy and proceed with publishing the relevant information in its website.

Article 7 SFDR: Sustainability Criteria at product level

When implementing the relevant investment decisions at product level, the AIFM considers both qualitative and quantitative criteria. The objective of the AIFM is to manage the managed AIF, which inter alia, operates in compliance with the EBRD’s Performance Requirements and the requirements of the AIFM`s E&S policy, which is integrated in its ESMS. Furthermore, an annual E&S report on the implementation of the procedures and the environmental and social performance of its portfolio companies is published.

Article 10 SFDR: Promotion of environmental or social characteristics and of sustainable investments

The AIFM does not engage in any commercial promotion of the managed AIF. In case such incident occurs, the AIFM will, within reasonable time, proceed with publishing the relevant information in its website.

Sustainability Disclosure

Non examination of the adverse impacts of investment decisions on sustainability factors

Regulatory Framework

Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosures in the financial services sector (known as the Sustainable Finance Disclosure Regulation – SFDR) aims to reduce information asymmetries regarding the integration of sustainability risks, the assessment of the main adverse effects on sustainability and the promotion of environmental or social characteristics, as well as sustainable investments, requiring financial market participants to make relevant disclosures to end investors.

Its gradual implementation began in March 2021 and the transparency it promotes, regarding the sustainability of financial products, aims to direct private capital towards sustainable investments, while preventing “green washing”.

Additionally, and bearing in mind Regulation (EU) 2019/2088, the European Commission published on April 6 2022 Regulation (EU) 2022/1288, through which are defined the technical standards, methodology and content of sustainability disclosures that participants in the financial markets are required to publish about their financial products.

According to Article 4 of Regulation (EU) 2022/1288, by June 30 of each year, participants in the financial markets are required to post in a separate section of their website a statement on the examination of the main adverse effects of their investment decisions on the sustainability factors. However, if such effects are not considered in the investment decisions of the participants, based on Article 12 of the Regulation, the participants in the financial markets are required to post on their website a statement about not considering the adverse effects of their investment decisions on the sustainability factors.

Declaration of non-consideration of the adverse effects of investment decisions on sustainability factors

The company “EOS Capital Partners” (hereinafter the Company) informs the stakeholders that it has established and implements a policy on the integration of sustainability risks in the process of making investment decisions and providing investment advice, as defined by the provisions of Regulation (EU) 2019/2088.

However, the Company states the following:

1. The Company does not currently take into account the adverse effects of investment decisions on sustainability factors in the absence of sufficient available data on these factors. However, the Company follows policies and practices of responsible investment both in its own operations as well as in its business activities, i.e. portfolio companies.
2. Once the above data on sustainability factors become available, the Company intends to modify its existing policy, adopting a specific process, to consider the main adverse effects of investment decisions on sustainability factors.

EOS Hellenic Renaissance Company II SCA, SICAV-RAIF (EHRFII)

Disclosures on the implementation of the Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088

Article 24 SFDR – Sections of website product disclosure for financial products that promote environmental or social characteristics

For financial products that promote environmental or social characteristics, financial market participants shall publish the information referred to in Article 10(1) of Regulation (EU) 2019/2088 and Articles 25 to 36 of this Regulation in the following order and made up of all of the following sections titled:
(a) Summary
(b) No sustainable investment objective
(c) Environmental or social characteristics of the financial product
(d) Investment strategy
(e) Proportion of investments
(f) Monitoring of environmental or social characteristics
(g) Methodologies
(h) Data sources and processing
(i) Limitations to methodologies and data
(j) Due diligence
(k) Engagement policies
(l) where an index is designated as a reference benchmark to attain the environmental social characteristics promoted by the financial product, ‘Designated reference benchmark’

Article 25 SFDR – Summary
EHRFII promotes environmental and/or social characteristics by assessing investees against Environmental, Social, and Governance (ESG) criteria using an ESG internal proprietary methodology, and by investing in companies that demonstrate adequate environmental, social and governance practices.
In any case, EOS ensures that those investments are made while maintaining the improvement of the ESG profile of the financial product. In addition, those investments are made in compliance with our internal processes, including the following minimum environmental or social safeguards,
through the exclusion of companies involved in controversies due to poor practices related to human and labour rights, environment, and corruption, as well as companies operating in sensitive sectors (tobacco, coal, controversial weapons,), as these companies are deemed to be in violation of international norms, or to cause unacceptable harm to society and/or the environment

Article 26 SFDR – No sustainable investment objective
EHRFII promotes environmental or social characteristics but does not have as its objective sustainable investment.

Article 27 SFDR – Environmental or social characteristics of the financial product
EHRFII aims to promote the improvement of ESG practices of investees within their sector of activity. The ESG performance of an entity is evaluated against a combination of environmental, social and governance characteristics including the ones below:

ENVIRONMENTAL
Air pollution/GHG emissions
Water use
Energy consumption
Compliance with environmental legislation

SOCIAL
Human Rights
Employee Training
Diversity & Equal opportunity
Occupational Health & Safety
Compliance with labor legislation

GOVERNANCE
Anti-bribery & Corruption
Internal Controls
Conflicts of interest
Whistleblowing mechanism
Personal data security
Compliance with corporate legislation

Article 28 SFDR – Investment strategy

EHRFII invests primarily through share capital increase and, in specific cases, more flexible financial structures (convertibles, preferred shares).
The fund will aim to finance non listed SMEs and Small Mid-Caps businesses that are innovative, profitable, healthy, operating in sectors with growth potential and aim to respect the climate and environmental standards and priorities of the European Union. Indicative sectors include food and beverage, digital/tech, selectively retail, healthcare services, logistics & transportation, selectively industrials.
EHRFII seeks that integration of ESG criteria (environmental, social and corporate governance criteria) effectively complements the existing investment process of the fund and aims to formulate an integrated investment policy that, in addition to adapting to regulatory requirements, creates the responsible investment management framework.

Article 29 SFDR – Proportion of investments

Aligned with E/S characteristics 90%

The remaining proportion of the investments may include:

• The proportion of assets that do not attain the minimum standard to meet environmental or social characteristics promoted by the financial product,
• Instruments which are mainly used for liquidity, efficient portfolio management, notably cash and term deposits

Article 30 SFDR – Monitoring of environmental or social characteristics

EOS monitors EHRFII portfolio companies on a regular basis for E&S risks and review the efficient implementation of related policies during the life of the investment in cooperation with a third-party service provider. Investees must report on E&S performance and provide relevant info on an annual basis.

Article 31 SFDR – Methodologies

With respect to overall ESG characteristics, EHRFII invests in companies with a minimum ESG scoring according to the internal proprietary methodology. Such ESG scoring is indicated in the annual report. The following weightings apply for the ESG scoring calculation, among several KPI’s depending on the sector and data quality.

Article 32 SFDR – Data sources and processing 

(a) the main data sources are the investee’s relevant departments
(b) quality of data is a priority through active participation of EOS in BoD’s
(c) the data are processed by third party service providers during the due diligence and the annually monitoring process
(d) the proportion of data subject to estimation will depend on the availability, the quality of data provided and the sector 

Article 33 SFDR – Limitations to methodologies and data

Limitations such as lack of data or lack of quality of data may occur, especially in small cap companies. Since the fund targets mainly small-mid cap companies, ESG best practices already apply in most cases. However, the fund will engage through its Environmental and Social Management System (ESMS) to improve the availability and the quality of data provided.

Article 34 SFDR – Due diligence

As part of the E&S due diligence process EOS ensures compliance with the Commission Communication (2021/C 58/01) “Technical guidance on the application of the ‘Do no significant harm’ principle under the Regulation establishing the Resilience and Recovery Facility’ prior to the investment decision. For this purpose, EOS applies the Commission’s technical guidance document on the sustainability proofing for the Invest EU Fund (Communication of the European Commission 2021/C 280/01),

The due Diligence report is prepared for the Investment Committee by a third-party service provider and includes the calculation of an “ESG score” of investee companies, based on a series of indicators including corporate governance, environmental and social criteria and considering Principal Adverse Impacts (PAIs) as outlined in Regulation (EU) 2019/2088. To be considered, the investee company shall meet a relevant ESG score threshold (minimum ESG score).

Article 35 SFDR – Engagement policies

EOS pursues, an active role in the decision-making of investee companies in particular through voting rights, taking care to avoid and/or manage any conflict-of-interest issues that may arise. Through dialogue with investee company management, visits, meetings and/or teleconferences, among others. EOS will encourage the disclosure of information on ESG issues, improving performance, reducing the risk profile, developing more sustainable business practices.

Article 36 SFDR – Designated reference benchmark

No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by EHRFII.

SFDR Annex (Article 8)   Download