🔷 SFDR Disclosure
1. Regulatory Context 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 (“SFDR”) forms part of the European Union’s broader strategy for sustainable finance under the EU Action Plan on Financing Sustainable Growth. The SFDR imposes transparency obligations on financial market participants and financial advisers with regard to the integration of sustainability risks, the consideration of adverse sustainability impacts, and the provision of sustainability-related information on financial products.
2. Integration of Sustainability Risks (Article 3 SFDR) The AIFM integrates sustainability risks into its investment decision-making process, to the extent that such risks are relevant and material. “Sustainability Risk” refers to an environmental, social or governance (ESG) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment. The assessment of sustainability risks is embedded within the overall risk management framework and due diligence procedures applied by the AIFM. Although the financial products currently managed by the AIFM are not marketed as ESG products under Articles 8 or 9 of SFDR, the AIFM acknowledges that sustainability risks may impact long-term risk-adjusted returns and therefore considers such risks as part of its fiduciary duty.
3. Principal Adverse Impacts (Article 4 SFDR) Consideration of Principal Adverse Impacts of Investment Decisions on Sustainability Factors In accordance with Article 4(1)(b) of the SFDR, [insert full legal name of the AIFM] does not currently consider the principal adverse impacts (“PAIs”) of investment decisions on sustainability factors at entity level. Given the size, scale and nature of its activities as a registered alternative investment fund manager (AIFM), and in light of the investment strategies of the financial products under management, which do not promote environmental or social characteristics or have a sustainable investment objective under Articles 8 or 9 SFDR, the AIFM considers such PAI disclosures to be disproportionate at this time. The AIFM continuously monitors regulatory developments and market standards and may reassess this position in the future.
4. Product Classification (Article 6 SFDR) At the date of this disclosure, the AIFM manages financial products that fall under Article 6 of SFDR: these do not promote environmental or social characteristics nor do they have sustainable investment as their objective. However, such products may still be exposed to sustainability risks depending on the nature of the underlying assets.
5. Taxonomy Regulation Disclosure In accordance with Article 7 of the Taxonomy Regulation (Regulation (EU) 2020/852), the investments underlying the financial products managed by the AIFM do not take into account the EU criteria for environmentally sustainable economic activities.
