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Sustainability at The Many

No consideration of adverse impacts of investment decisions on sustainability factors

Date: 30/01/2023

This Principal Adverse Impact Statement (“PAI Statement”) is published subject to 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 (the “SFDR”) article 4.

The Many AIFM A/S (“The Many”) does not consider the adverse impacts of investment decisions on sustainability factors. However, The Many does consider ESG factors and sustainability risks as part of the Fund’s investment processes. The Many is strongly committed to considering sustainability risks as part of our general business activities, hereunder, but not limited to our investment decisions.

Adverse impacts on sustainability factors refers to the investment’s negative impacts on environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

Annex I of Commission Delegated Regulation (EU) 2022/1288 supplementing the SFDR (the “RTS”) includes a template “principal adverse sustainability impacts statement” with adverse sustainability impact indicators that an entity considering principal adverse impacts shall consider, report, and set targets in relation to.

The Many has decided not to consider principal adverse impacts because:

  • all investments in the alternatives investment funds that The Many manages are real estate funds and are characterized as article 6 funds according to SFDR; and
  • given the small size of the organization, such measurements, reporting and other actions to meet the optional disclosure requirement would currently not be proportional; and
  • there are yet no established processes to acquire reliable data and measure all the indicators under SFDR Delegated Regulation.

This decision is the consequence of an analysis, where The Many, due to the size of the organization and the nature of the currently managed funds, finds that it may damage The Many’s profitability with a negative impact to its investors within the current scope of the managed funds’ investment strategies as of today. When The Many manages funds that are either promoting environmental or social characteristics (SFDR Article 8) or has sustainability as its investment objectives (SFDR Article 9), this decision will be reassessed.

For more information on sustainable investments, please see Sustainable Investment Policy. 

For more information on remuneration, please see the Remuneration below.


It is pivotal to The Many AIFM A/S’ remuneration policy that unnecessary risk taking is avoided, also in respect to sustainability related risk. Remuneration at The Many AIFM A/S primarily comprises a fixed salary; however certain key employees have a variable component to the salary as well. The variable component is approved by the Board and must take sustainability related risks into account and ensure, that de-prioritization of sustainability risks is not related to the achievement of the variable component.

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© The Many A/S. Alle rettigheder forbeholdes. The Many AIFM A/S er et dansk selskab, CVR-nr: 39328232, LEI-kode: 984500003CF0A72FEF45, og har tilladelse af Finanstilsynet i Danmark til at forvalte alternative investeringsfonde (FAIF) med FT-nr. 23160. The Many er et EU-varemærke som tilhører The Many A/S.