FundRock LIS S.A. ESG-Policy
Financial Market Participant's non-consideration of adverse impacts on investment decisions on sustainability factors
Without prejudice to any different and exceptional fund-specific approach or reasoning as specifically agreed with the relevant fund, having embedded the relevant due diligence policies in the relevant investment decisions applicable to those funds as separately disclosed on this website, FundRock LIS S.A. will generally not consider adverse impacts of investment decisions on sustainability factors due to absence of (i) sufficient data/information from portfolio companies/investments and (ii) sufficient quality of such data/information to provide a meaningful assessment on the performance of any potential adverse impact of the investment decisions on sustainability factors in view, amongst others, of their heterogeneity (e.g. geography, size, sector).
FundRock LIS S.A. will re-evaluate its position on the matter on a yearly basis and as required by the relevant regulation(s).
Product specific Sustainability-related disclosures
A/O expects to mitigate, where possible, the negative impact of investment decisions on factors such as environmental, social and employee matters, human rights, corruption and bribery matters. Currently A/O Built Technologies II SCSp does not assess Principal Adverse Impacts of investment decisions as specifically prescribed under SFDR (Sustainable Finance Disclosure Regulation), as our assessment conforms to our own ESG policy and internal methodology applicable to our portfolio. A/O is monitoring the development SFDR regulation and is committed to reviewing its position on a regular basis.
A/O Built Technologies II SCSp ESG Policy
In relation to AARO MARKET NEUTRAL CRYPTO MULTIFUND S.A. SICAV-RAIF, the AIFM and the Portfolio Manager have evaluated the requirements of the principle adverse impact (“PAI”) on sustainability factors in 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”). They are of the view that for the time being, it is not possible to meaningfully forecast the adverse impacts of investment decisions on Sustainability Factors. Indeed, there are no sufficient data and/or information of satisfactory quality and no adequate methodologies at this time to properly assess the adverse impact of the investment decisions on sustainability factors for the strategy at hand.
The AIFM and the Portfolio Manager will review this approach and will formally re-evaluate the decision and work towards developing more data over time in order to facilitate such considerations.
While the Sponsor does not strictly consider the adverse impacts of investment decisions in the manner prescribed by the SFDR, it does broadly considers the adverse impacts of investment decisions in relation to its portfolio investments.
The Sponsor assesses the environmental aspects and safety and health risks of all operations, activities and services, and incorporates practical procedures and controls designed to prevent adverse impacts. The Sponsor also designs operational practices for its portfolio investments to reduce, reuse and recycle waste materials, and to mitigate adverse impacts on the environment, and the conservation of natural resources. The Sponsor undertakes these assessments and designs as part of its ongoing ESG oversight of its portfolio investments.
For website disclosures related to Alinda Infrastructure Fund IV (Euro), SCSp, under the Sustainable Finance Disclosure Regulation please refer to the attached file:
In accordance with SFDR, the Fund shall include in this Offering Memorandum, in relation to each Sub-fund, a description of the manner in which Sustainability Risks are integrated into their investment decisions and the results of the assessment of the likely impacts of Sustainability Risks on the returns of the financial products they make available.
The Sub-Fund and the appointed Portfolio Manager define integration of environmental, social and governance characteristics (ESG) as the consistent consideration of material Sustainability Risks into the investment research process to enhance the investors' risk-adjusted returns.
Alpha Intelligence Capital Fund II, SCSp, SICAV-RAIF will generally not consider adverse impacts of investment decisions on sustainability factors due to the absence of (i) sufficient data/ information and (ii) sufficient quality of such data/ to provide a meaningful assessment on the performance of any potential adverse impact of the investment decisions on sustainability factors in view of the lack of relevant information from target companies/investments in the Private Equity and Venture Capital industry. Generally, given the nature of the asset class (i.e., early-stage Investments in AI Companies), there is not expected to be any material adverse impacts through the Partnership’s Investments.
The below statement applies to CAM Infrastructure Strategies, S.C.S. SICAV-RAIF, CAM Private Equity Strategies, S.C.S. SICAV-RAIF and VB Private Equity S.C.S-RAIF:
AltamarCAM integrates sustainability risks into its investment decisions and investment advice
Altamar Private Equity, S.G.I.I.C., S.A.U. and CAM Alternatives GmbH (hereinafter and jointly, “AltamarCAM”) are subject to the Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector, (hereinafter “SFDR” or the “Regulation”).
AltamarCAM integrates sustainability risks into its investment advice. To enhance transparency and inform end investors, the policies on the integration of these risks, as required by Article 3 of the SFDR, are included in the ESG Policy.
The Remuneration Policy includes information on how the remuneration system is consistent with the integration of sustainability risks, as established in Article 5 of the Regulation.
No consideration of adverse impacts of investment decisions on sustainability factors
Altamar Private Equity, S.G.I.I.C., S.A.U. and CAM Alternatives GmbH (henceforth and combined, “AltamarCAM”) do not consider nowadays adverse impacts of investment advice on sustainability factors, in the manner prescribed by Article 4 of the SFDR.
The nature of the vehicles advised by AltamarCAM (mainly fund of funds) implies that to consider adverse sustainability impacts, AltamarCAM should receive from the managers of the underlying funds the mandatory information in order to comply with the regulation, currently being principal adverse impacts not available to all underlying managers (in the way these indicators are formulated in the Annex I of Commission Delegated Regulation (EU) 2022/1288).
AltamarCAM takes sustainability and ESG very seriously, using its own procedures, policies and metrics to assess the adverse impacts of investment decisions on sustainability factors not-aligned with those prescribed under Article 4 of the SFDR and the Annex I of Commission Delegated Regulation (EU) 2022/1288, as AltamarCAM considers that these are more appropriate and tailored to AltamarCAM and the investments that AltamarCAM makes on behalf of its funds, and therefore assist in AltamarCAM’s objective to deliver long-term risk-adjusted returns to investors.
AltamarCAM expects to keep this position under review by reference to applicable market developments and future availability of information, and then, consider the adverse impacts of both the investment decisions and the investment advice on sustainability factors.
For the relevant website disclosures related to Apax XI EUR and Apax XI USD funds under the Sustainable Finance Disclosure Regulation please refer to the attached file:
The below is applicable to Apera Private Debt Fund I SCSp, Apera Private Debt Fund II SCSp and Apera Bond S.C.S. SICAV-RAIF: Apera Asset Management GmbH is required to publish information on whether it considers the “adverse impacts of investment decisions on sustainability factors” (the “Principal Adverse Impacts”) under the SFDR. Apera Asset Management GmbH does not currently consider the Principal Adverse Impacts of investment decisions on sustainability factors in connection with its products and services. This is because Apera Asset Management GmbH is not currently in a position to obtain and/or measure all the data that it would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost. This is in part because underlying investments are not widely required to, and may not currently, report by reference to the same data. Date of publication: 10 March 2021.
For the relevant website disclosures related to Apera Private Debt Fund III SCSp and Apera Private Debt Fund III (USD) SCSp under Article 10 of the Sustainable Finance Disclosure Regulation please refer to the below files:
Apera Private Debt Fund III SCSp - Article 10 Disclosure
Apera Private Debt Fund III (USD) SCSp - Article 10 Disclosure
For the relevant website disclosures related to Beaufort Capital Real Estate Debt Fund III LP under Article 10 of the Sustainable Finance Disclosure Regulation please refer to the attached file:
Beka Investments does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
The below Article 3 and Article 4 disclosures are applicable for:
BGO Europe (Lux) IV Sidecar 2 SCSp
BGO Europe IV Tiger Co-Investment
BentallGreenOak Europe Core Plus Logistics SCSp SICAV RAIF
BentallGreenOak Europe (Lux) IV SCSp
BentallGreenOak US Core Plus (Lux) Fund SCSp
GO Europe SLP II, SCSp SICAV-SIF
GreenOak Europe (Lux) III SCSp
GreenOak Europe Core Plus Logistics SCSp
GreenOak Europe Core Plus Logistics Feeder S.C.A SICAV-RAIF
GreenOak Europe Core Plus Logistics Feeder II S.C.A. SICAV-RAIF
GreenOak Europe Core Plus Logistics Parallel SCSp
GreenOak Europe Secured Lending II SLP
GreenOak Europe Secured Lending SLP
GreenOak Tactical Lending SLP
GreenOak US (EU Parallel) II S.C.S., SICAV-SIF
For the relevant website disclosure related to BentallGreenOak Europe Secured Lending III SLP under Sustainable Finance Disclosure Regulation please refer to the attached file:
For the relevant website disclosure related to BentallGreenOak Europe Tactical Lending II SLP under Sustainable Finance Disclosure Regulation please refer to the attached file:
For the relevant website disclosure related to BentallGreenOak Luxembourg Funds SCSp SICAV - RAIF Prime Canadian Property Fund under Sustainable Finance Disclosure Regulation please refer to the attached file:
All investment decisions in relation to the Fund broadly consider the principal adverse impacts of those decisions on sustainability.
Please refer to the below documentation for further details on the methodologies and approaches:
The below statements apply to the below funds (the “Funds”):
- BID Equity Fund II-A, SCSp
- BID Equity Fund II-B, SCSp
- BID Equity Overflow Fund II-A, SCSp
- BID Equity Overflow Fund II-B, SCSp
Pursuant to the Limited Partnership Agreements (LPA), the investment objective of the Funds is to build, hold and manage directly or indirectly a portfolio of equity investments in software companies primarily based in the DACH region (Germany, Austria and Switzerland).
The Funds do neither incorporate any ESG principles in their investment strategy, nor do the Funds promote any environmental or social characteristics or a combination of these. Investing in small-cap B2B software companies mainly in the DACH region, where also the vast majority of portfolio companies’ customers operates their businesses, there is no link to typical ESG issues regarding the Funds´ portfolio companies’ business models. Therefore, the Funds will not consider any principle adverse impacts on sustainability factors of their investment decisions.
Blue Like an Orange Sustainable Capital Fund SICAV-SIF SCS does consider principal adverse impacts of investment decisions on sustainability factors. Relevant details are included in the Fund specific ESG Policy.
Article 10 Disclosures:
Blue Like an Orange - Latin America Fund I
Blue Like an Orange - Latin America Fund II
Blue Like an Orange - Latin America Feeder Fund II
PAI Reporting:
Annex I SFDR RTS - Latin America Fund I
BMW i Ventures SCS SICAV RAIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
The below statement applies to:
- Boston Capital Income and Value U.S. Apartment Fund SICAV-SIF
- Boston Capital Income and Value U.S. Apartment Fund II- A and B
The Funds will not be considering principal adverse impacts on sustainability factors at this time. Although the Funds may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is subject to ongoing review as we further develop our processes in this respect.
For the time being the fund does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to the difficulty to obtain necessary information and lack of relevant disclosures from target investments.
For the relevant website disclosures related to the Fund under the Sustainable Finance Disclosure Regulation please refer to the attached files:
CNF SFDR Website Art 10 Disclosure
China Central and Eastern Europe Investment Co-Operation Fund SCS SICAV-SIF and China Central and Eastern Europe Investment Co-Operation Fund II SCS SICAV-SIF will not be considering principal adverse impacts on sustainability factors at this time. Although the Fund may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.
CKPF SLP - Article 4 Statement
For the ESG/SFDR disclosure please refer to the dedicated webpage here:
For the relevant website disclosures related to Climate Asset Management - Natural Capital Fund A under the Sustainable Finance Disclosure Regulation please refer to the attached files:
PAI Reporting:
For the relevant website disclosures related to Climate Asset Management – Nature Based Carbon Fund A and B under the Sustainable Finance Disclosure Regulation please refer to the attached file:
PAI Reporting:
For the relevant website disclosures related to CGV Sustainability I SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached files:
Coller Credit Opportunities I - Annex I, SLP - Article 4 Statement
For the ESG/SFDR disclosure please refer to the dedicated webpage here:
Coller Credit Opportunities I - D, SLP - Article 4 Statement
For the ESG/SFDR disclosure please refer to the dedicated webpage here:
All investment decisions in relation to the Fund broadly consider the principal adverse impacts of those decisions on sustainability.
Please refer to the below documentation for further details on the methodologies and approaches:
For the relevant website disclosures related to CT UK Residential Real Estate FCP-RAIF under the Sustainable Finance Disclosure Regulation please refer to the attached files:
The below statement refers both to DESCOPEDIA SELECT STRATEGIES as well as DESCOPEDIA ASIA: The AIFM does not consider the adverse impacts of investment decisions on Sustainability Factors, (i) as no sufficient data of satisfactory quality is available to allow the AIFM to adequately assess the potential adverse impact of the investment decision on Sustainability Factors, (ii) because of a lack of relevant disclosures from target investments and (iii) as there are no adequate methodologies to calculate the potential adverse impact of the investment decision on Sustainability Factors.
The below statement refers to DF Deutsche Finance 711 Investment S.C.S., DF Deutsche Finance 711 Investment III S.C.S.:
For this funds Sanne LIS S.A. together with the Investment Adviser decided not to consider principle adverse impacts of investment decisions on sustainability factors due to the absence of sufficient data/information.
DTC believes in the societal and business benefits of a responsible Environmental, Social and Governance (ESG) policy. Through its investment advisory processes, DTC seeks to identify, grow and improve the Funds’ portfolio companies it advises, ensuring a long-term sustainable value creation. DTC recognizes that ESG principles can contribute to creating value for investors and all other stakeholders – both in terms of mitigating risks and seizing opportunities. However, for the time being the funds advised by DTC – and therefore DTC itself – do not consider the adverse impacts of investment decisions on ESG factors within the meaning of Art. 4 SFDR. This decision is mainly based on the absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment advise on Sustainability Factors as well as due to lack of relevant disclosures from target investments that are – as of now – in general not legally obliged to report on sustainability data. The data situation may change once the Corporate Sustainability Reporting Directive is fully implemented and in force and there are additional guidelines from the authorities for (voluntary) sustainability reporting also for small and medium enterprises. DTC will re-evaluate the conditions in the end of 2024. As soon as DTC starts considering adverse sustainability impacts of its investment advice, DTC will disclose the relevant information to investors and on this website.
For the relevant website disclosures related to Digital Infrastructure Vehicle II SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached file:
DTC believes in the societal and business benefits of a responsible Environmental, Social and Governance (ESG) policy. Through its investment advisory processes, DTC seeks to identify, grow and improve the Funds’ portfolio companies it advises, ensuring a long-term sustainable value creation. DTC recognizes that ESG principles can contribute to creating value for investors and all other stakeholders – both in terms of mitigating risks and seizing opportunities. However, for the time being the funds advised by DTC – and therefore DTC itself – do not consider the adverse impacts of investment decisions on ESG factors within the meaning of Art. 4 SFDR. This decision is mainly based on the absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment advice on Sustainability Factors as well as due to lack of relevant disclosures from target investments that are – as of now – in general not legally obliged to report on sustainability data. The data situation may change once the Corporate Sustainability Reporting Directive is fully implemented and in force and there are additional guidelines from the authorities for (voluntary) sustainability reporting also for small and medium enterprises. DTC will re-evaluate the conditions in the end of 2024. As soon as DTC starts considering adverse sustainability impacts of its investment advice, DTC will disclose the relevant information to investors and on this website.
For the relevant website disclosures related to DIV II Matrix Co-Invest II SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached file:
Article 10 disclosure - Summary of the Sustainable Finance Disclosures - NL
Article 10 disclosure - Summary of the Sustainable Finance Disclosures - NO
Article 10 disclosure - Summary of the Sustainable Finance Disclosures - SE
Article 10 disclosure - Summary of the Sustainable Finance Disclosures - SK
Article 10 disclosure - Summary of the Sustainable Finance Disclosures - FR
Article 10 disclosure - Summary of the Sustainable Finance Disclosures - GR
Article 10 disclosure - Summary of the Sustainable Finance Disclosures - IT
Article 10 disclosure - Summary of the Sustainable Finance Disclosures - DK
Article 10 Disclosure - Summary of the Sustainable Finance Disclosures - ES
Article 10 Disclosure - Summary of the Sustainable Finance Disclosures - FI
Neither DR Sachwerte SCS, SICAV-RAIF, nor VB Sachwerte SCS, SICAV-RAIF consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
For the relevant website disclosures related to DS Renew I SCA SICAV-RAIF under the Sustainable Finance Disclosure Regulation please refer to the attached file:
DTC believes in the societal and business benefits of a responsible Environmental, Social and Governance (ESG) policy. Through its investment advisory processes, DTC seeks to identify, grow and improve the Funds’ portfolio companies it advises, ensuring a long-term sustainable value creation. DTC recognizes that ESG principles can contribute to creating value for investors and all other stakeholders – both in terms of mitigating risks and seizing opportunities. However, for the time being the funds advised by DTC – and therefore DTC itself – do not consider the adverse impacts of investment decisions on ESG factors within the meaning of Art. 4 SFDR. This decision is mainly based on the absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment advice on Sustainability Factors as well as due to lack of relevant disclosures from target investments that are – as of now – in general not legally obliged to report on sustainability data. The data situation may change once the Corporate Sustainability Reporting Directive is fully implemented and in force and there are additional guidelines from the authorities for (voluntary) sustainability reporting also for small and medium enterprises. DTC will re-evaluate the conditions in the end of 2024. As soon as DTC starts considering adverse sustainability impacts of its investment advice, DTC will disclose the relevant information to investors and on this website.
For the relevant website disclosures related to DTCP Growth Equity III SCSp, SICAV-RAIF under the Sustainable Finance Disclosure Regulation please refer to the attached file:
The AIFM, Egeria Master SCA, SICAV-RAIF and Egeria Feeder SCA, SICAF-RAIF have considered, and continue to consider, ESG factors in their investment process but they do not, at this stage, consider adverse impacts of investment decisions on sustainability factors within the meaning of Article 7(2) of the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (the “SFDR”). The AIFM and Egeria Master SCA, SICAV-RAIF have chosen not to do so for the present time as they consider, among other reasons, that the Sub-Fund’s existing ESG policies and procedures are appropriate, proportional, and tailored to the investment strategy of its funds and that the AIFM is not, in its view, currently in a position to obtain and/or measure all the data which it would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost with respect to all its investment strategies to clients and investors. This is in part because underlying investments are not widely required to, and may not currently, report by reference to the same data. The AIFM and Egeria Master SCA, SICAV-RAIF continue to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance and will, where required or otherwise appropriate, make changes to its existing policies and procedures.
For the relevant website disclosures related to EMERAM Private Equity Fund II SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached file:
The Fund considers the main material or potentially material adverse impacts (“PAIs”) of the Fund's Investments on sustainability factors. These are identified during the due diligence phase of the Investments of the Fund and their evolution is continuously monitored during the ownership phase. Ultimately, the Fund will pursue a reduction of negative externalities caused by the Investments. The due diligence process will adhere to responsible business conduct codes and internationally recognised standards for due diligence and reporting, such as the due diligence for responsible business conduct developed by the OECD and will be aligned with the Paris Agreement’s main goal to make finance flow towards low-carbon technologies and ultimately pursue efforts to limit the temperature increase to 1.5 degrees Celsius above pre-industrial levels.
The indicators used to measure the main adverse impacts will be in line with EU regulations, more specifically with the environmental (GHG emissions, water and waste management) and social (board gender diversity, gender pay gap, etc.) indicators included in the regulatory technical standards of the SFDR (“RTS”). These indicators may be subject to customization based on the specific characteristics of each target and Portfolio Company and could be eventually updated in line with the evolving applicable EU legislation and the international best practices in this context. Information on the PAIs on sustainability factors will be integrated into the periodic information that investors will receive and will be reported to them before June 30, 2023 (and thereafter each year before June 30 of the following years) in line with the RTS.
Energy Transition Investments S.C.A. SICAV-RAIF ESG Policy
Energy Transition Investments S.C.A. SICAV-RAIF Disclosures
Energy Transition Investments Engagement Policy
PAI Reporting:
For the relevant website disclosures related to Energy Access Acceleration Fund SA, SICAV-RAIF under the Sustainable Finance Disclosure Regulation please refer to the attached files:
No consideration shall be made for ‘principal adverse impact on sustainability factors’, the Partnership will reconsider this position on a regular basis and will endeavor to research and develop instruments or methodologies to efficiently address relevant PAIs to be able to disclose the position of our investment companies.
The fund strategy targets Dutch lower middle market businesses where: i) available sustainability related information is limited and inconsistent in scope and subjective in its nature; and ii) the cost of doing proper due diligence relative to the size business and loans is disproportionate.
Enterprising finance the Netherlands Unitranche Fund SCSp - Article 10 Disclosure
For the relevant website disclosures related to Equitix European Infrastructure II SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached file:
For the relevant website disclosures related to Equitix Infra Ireland SCSP SICAV-RAIF under the Sustainable Finance Disclosure Regulation please refer to the attached file:
For the relevant website disclosures related to Equitix Sustainable Greenfield Fund SCSp SICAV-RAIF under the Sustainable Finance Disclosure Regulation please refer to the attached files:
European Grocery Club Deal Investment SCSp (the “Partnership”) does not have sustainable investment as its objective (within the meaning of Article 9 of the SFDR) and is not intended to promote specific environmental or social characteristics (within the meaning of Article 8 of the SFDR). The Partnership does not integrate Sustainability Risks as the Partnership is an access point for investors to make an indirect underlying commitment to SERE III Portfolio Investments SCSp (the “Master Fund”) and the Partnership does not conduct investment decision making. As the investment strategy of the Partnership is to invest in the Master Fund, the Partnership defers to any consideration of Sustainability Risks undertaken by the Master Fund.
At present, Sanne LIS S.A. (the “AIFM”) of the Partnership (and/or its delegate) does not, within the meaning of Article 4(1)(a) of the SFDR, consider the adverse impacts of its investment decisions on sustainability factors. The Partnership’s AIFM (and/or its delegate) does not currently do so because, among other reasons, it considers its existing ESG policies and procedures to be appropriate, proportional and tailored to the investment strategies of the Fund. The AIFM intends to continually review this position and work towards developing more data over time in order to facilitate such considerations.
We currently do not formally, or to the extent set out in SFDR, take into account the principal adverse impacts of investment decisions on sustainability factors on the basis that, in the context of the investment strategies of our funds, it is not possible to conduct detailed diligence on the principal adverse impacts.
The below statements are applicable to EQT Exeter China Logistics Fund SCSp, Exeter Europe Logistics Value Fund IV S.C.SP , Exeter Europe Logistics Value Fund IV Feeder S.C.Sp , Exeter Europe Industrial Core Fund S.C.Sp. , Exeter Europe Industrial Core Fund Feeder S.C.Sp. Exeter is committed to addressing sustainability across its real estate assets through a responsible approach to economic, environmental and social aspects through all phases of the property investment cycle. Generally this means:
> Strategically focusing efforts on identifying material risks
> Assessing trends to anticipate opportunities for value creation and manage existing risk appropriately
> Establishing internal processes to assess, identify, address and progress on these opportunities and risks. This is primarily done through our in-depth due diligence process upon acquisitions and these are factored into our risk analysis for our investments.
Franklin Templeton Social Infrastructure Fund, SCA does consider principal adverse impacts of investment decisions on sustainability factors. For relevant details please refer to the Article 4 statement below.
For the relevant website disclosures related to Franklin Templeton Social Infrastructure Fund SCA SICAV SIF under the Sustainable Finance Disclosure Regulation please refer to the attached files:
FUNIS Infrastructure Investments S.C.S., SICAV-RAIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data and lack of relevant disclosures from small target investments for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors.
For website disclosures related to GAIA AFRICA CLIMATE FUND S.A., SICAV-RAIF, under the Sustainable Finance Disclosure Regulation please refer to the attached file:
Article 10 Disclosure
Sanne LIS S.A. as alternative investment fund manager of GALLICA III SARL SICAV-RAIF (the “Fund”) together with the Investment Adviser of the Fund, BRG ASSET MANAGEMENT LLC, does not consider the principle adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
For the time being the fund does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
For the relevant website disclosures related to GTIS US PIP under Sustainable Finance Disclosure Regulation please refer to the policy document here.
For website disclosures related to the Hamilton Funds, under the Sustainable Finance Disclosure Regulation please refer to the attached files:
Article 10 Disclosure - Hamilton Lane Senior Credit Opportunities Fund S.A. SICAV RAIF
Article 10 Disclosure - Hamilton Lane European Investors SCA SICAV-RAIF Impact II Parallel Sub-Fund
Article 10 Disclosure - Hamilton Lane GLOBAL PRIVATE ASSETS FUND SICAV
Applicable for:
- H.I.G. Bayside Loan Opportunity Fund II (Europe - Euro), SCSp
- H.I.G. Bayside Loan Opportunity Feeder Fund II (Europe - Euro), SCSp
- H.I.G. Europe Realty Partners III, SCSp
- H.I.G. Whitehorse Luxembourg Loan Feeder Fund - 2020, SCSp
- H.I.G. Infrastructure Partners C, L.P.
- H.I.G. WhiteHorse Europe Unlevered Direct Lending Fund II SCSp
- H.I.G. WhiteHorse Europe Levered Direct Lending Fund II SCSp
The Funds will not be considering principal adverse impacts on sustainability factors at this time. Although the Funds may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.
For the relevant website disclosures related to the following Funds, please refer to the below links:
- H.I.G. Infrastructure Partners C, L.P.
- H.I.G. WhiteHorse Europe Unlevered Direct Lending Fund II SCSp
- H.I.G. WhiteHorse Europe Levered Direct Lending Fund II SCSp
- H.I.G. Bayside Loan Opportunity Fund II (Europe - Euro), SCSp
- H.I.G. Bayside Loan Opportunity Feeder Fund II (Europe - Euro), SCSp
- H.I.G. Middle Market Europe LBO Fund II SCSp
Article 10 Disclosure - H.I.G. Infrastructure Partners C, L.P.
Summary Translation - H.I.G. Infrastructure Partners C, L.P
Article 10 Disclosure - H.I.G. WhiteHorse Europe Unlevered Direct Lending Fund II SCSp
Summary Translation - H.I.G. WhiteHorse Europe Unlevered Direct Lending Fund II SCSp
Article 10 Disclosure - H.I.G. WhiteHorse Europe Levered Direct Lending Fund II SCSp
Summary Translation - H.I.G. WhiteHorse Europe Levered Direct Lending Fund II SCSp
Article 10 Disclosure - H.I.G. Bayside Loan Opportunity Fund II (EUROPE-EURO), SCSP
Summary Translation - H.I.G. Bayside Loan Opportunity Fund II (EUROPE-EURO), SCSP
Article 10 Disclosure - H.I.G. Middle Market Europe LBO Fund II SCSp
Summary Translation - H.I.G. Middle Market Europe LBO Fund II SCSp
For the Article 4 statement applicable to Harrison Street property Fund B S.C.S., SICAV-RAIF, please refer to the below document.
HARRISON STREET CORE PROPERTY FUND B S.C.S., SICAV-RAIF
PAI Reporting:
HF Private Debt Fonds SCSp and HF Private Debt Fonds II SCSp do not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector dated 27 November 2019 (“SFDR”)
TRANSPARENCY OF SUSTAINABILITY RISK POLICIES (Article 3, SFDR)
Hg Pooled Management Limited and its affiliates (“Hg” or “we”) considers sustainability risks associated with investment opportunities including but not limited to risks associated with climate change, health & safety, cybersecurity and bribery and corruption. In particular, Hg evaluates environmental, social and governance (“ESG”) risks, mitigating factors and opportunities applicable for the asset type, geography and the industry as a whole. Hg tracks relevant data, and, where appropriate, integrates such data into the investment research, acquisition and onboarding and post-acquisition, value creation and realisation, risk monitoring and exit processes. Hg’s targeted investment approach means they have extensive knowledge and a clear focus on the ESG metrics that are most material to the software and service sector. These ESG metrics are outlined in Hg’s Sustainable Business framework Hg maintains a Responsible Investment Policy that sets out its approach to the identification and management of sustainability and ESG related risks and opportunities throughout the investment activities, including the management of investee companies. HgCapital LLP has been a signatory to the United Nations Principles for Responsible Investment (“UNPRI”) since 2012 and is dedicated to the UNPRI’s six principles. Further information on Hg’s policies on the integration of sustainability risks in our investment decision‐making process is located on Hg’s website at: Hg | Responsibility.
NO CONSIDERATION OF ADVERSE SUSTAINABILITY IMPACTS AT ENTITY LEVEL (Article 4, SFDR)
While Hg will continue to take into account ESG factors in its investment process, Hg does not consider adverse impacts of investment decisions on sustainability factors as set out in the SFDR. Hg has chosen not to do so presently as they consider that their existing ESG approach is appropriate, proportionate and tailored to the investment strategy they currently pursue. While Hg does not currently intend to consider adverse impacts of investment decisions on sustainability factors, they continue to monitor regulatory developments with respect to the SFDR and other relevant laws and regulations, including the implementation of related and secondary legislation and regulatory guidance. Where required or otherwise appropriate, Hg will accordingly make changes to its existing policies and procedures.
TRANSPARENCY OF SUSTAINABILITY RISK POLICIES (Article 5, SFDR)
Hg pays their staff a combination of fixed remuneration and variable remuneration. Variable remuneration for relevant staff takes into account compliance with all of Hg’s policies and procedures, including those relating to risk management and the integration of sustainability risks. ESG is embedded into the performance process through one performance objective, applying across all teams, which relates to how the employee has contributed to ESG & Diversity across the firm or its portfolio. Furthermore, variable remuneration also depends on the performance against Hg’s values as part of the annual review process. One of Hg’s values is ‘Win right’ where the employees are asked to consider the firm’s long-term ESG performance.
Article 10 disclosure Hg Mercury 4
Article 10 disclosure Hg Titatn 2
Article 10 disclosure HG Saturn 3 (Lux) SCSp
Article 10 disclosure HG Genesis 10 (Lux) SCSp
Article 10 disclosure HG Saturn 4 (Lux) SCSp
Article 10 disclosure HG Saturn 4 (Lux) SCSp (French Summary)
While Hillwood Development Company does not currently consider principal adverse impacts on sustainability factors in its investment advice due to the nature of the underlying investments, investment mandates and availability of underlying data we may consider sustainability as part of our investment process and are continuing to evaluate our processes.
For website disclosures related to HQ Capital IV SCS SICAV-RAIF – Auda Deep Impact Fund under Article 10 of the SFDR please refer to Sustainability-related disclosures on the Sponsor's dedicated webpage here:
https://www.hqcapital.com/de/sfdr-disclosure
Article 10 Disclosure - Danish
Article 10 Disclosure - Finnish
Article 10 Disclosure - German
Article 10 Disclosure - Italian
For the relevant website disclosures related to HSBC Alternative Investments S.C.A. SICAV-RAIF (Impact Basket) under the Sustainable Finance Disclosure Regulation please refer to the attached file:
The fund does not consider the adverse impacts of investment decisions on ESG factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
Applicable for HSBC Alternative Investments S.C.A. SICAV-RAIF – Sub-Fund III (Buyout Basket III)
The Sub-Fund does not consider the principal adverse impacts of investment decisions on sustainability factors due to the fact that it will invest in a blind pool of target funds, which does not guarantee access to the relevant information and necessary data. If the required information and data will be made available by the managers of the target funds in the future, the principal adverse impacts on sustainability factors may be taken into account (if relevant) at a later point in time.
The AIFM currently considers principal adverse impacts and its reporting not relevant for the Sub-Fund as it does not reflect the way in which the Sub-Fund is either operated or sold to investors. For this Sub-Fund, the AIFM considers that the processes already in place in relation to, inter alia, the integration of sustainability risks into investment decisions are sound from a risk perspective.
Applicable for HSBC Alternative Investments S.C.A. SICAV-RAIF – Sub-Fund V (Impact Basket II)
The Sub-Fund takes into account all the mandatory indicators for principal adverse impacts on sustainability factors (“PAI”) and certain voluntary PAIs, which are considered to be relevant based on the Sub-Fund’s specific investments. Information on the PAIs will be provided in the annual report of the Sub-Fund.
HV Fund SCS RAIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
For the relevant documents related to ISQ Energy Transition Infrastructure Fund under the Sustainable Finance Disclosure Regulation please refer to the attached files:
Jefferies Finance has considered, and continues to consider, ESG factors in its investment process but it does not, at this stage, consider adverse impacts of investment decisions on sustainability factors as specifically contemplated by the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (the “SFDR”).
Jefferies Finance has chosen not to do so for the present time as it considers its existing ESG principles and diligence procedures to be appropriate, proportional and tailored to the investment strategy of Jefferies Finance funds. Jefferies Finance continues to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance and will, where required or otherwise appropriate, make changes to its existing policies and procedures.
KLAR Partners does not consider the adverse impacts of investment decisions on sustainability factors.
KLAR Partners is a UK-based manager that currently only markets one of its products under Art 42 AIFMD into the EU. Given the limited exposure of the entity and its other products to SFDR reporting requirements, as well as incomplete or insufficient data in respect of adverse impacts of investment decisions on sustainability factors, KLAR Partners will not report on adverse impacts on sustainability factors at this time.
KLAR will keep this position under review and may consider adverse impacts of investment decisions on sustainability factors when, for example, multiple products fall in-scope of the SFDR, data required for reporting is more readily available, or the manager is subject to investor request or specific NCA (National Competent Authority) jurisdictional requirements.
KLAR Partners will continue to review its position on SFDR entity level disclosures on a no less than annual basis
KLAR Partners II SCSp - Article 10 Disclosure
The below statements are applicable for:
- KÖZU Private Markets 13 SICAV RAIF SCA
- KÖZU Private Markets 17 SICAV RAIF SCA
The fund does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
At this stage, the fund is not considering the principle negative impact of investment decisions on sustainability factors and a change in this approach is currently not intended. Considering the nature and structure of the fund's underlying investments, the collection of the necessary data on the relevant sustainability indicators is as such not possible.
For the relevant website disclosures related to Lightrock Climate Impact Fund SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached files:
PAI reporting:
For the relevant website disclosures related to Lightrock Growth Fund II SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached files:
Long Harbour Euro Secured Income I Fund. The Fund’s strategy does not have an ESG focus but investment decisions taken by the portfolio manager does take into consideration environmental and the impact of investment decisions on sustainability factors as detailed in the Fund´s ESG Policy.
M-Alternative Investment Fund (S.C.A.) SICAV-SIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
The Fund does not consider the principal adverse impacts of investment decisions on sustainability factors and currently does not intend to do so in the future. The nature and structure of the Fund’s underlying investments do not allow it to collect the necessary data on the relevant sustainability indicators.
For the Article 4 statement applicable all MADISON INTERNATIONAL REAL ESTATE LIQUIDITY FUND VI, SCS, please refer to the document.
Meso Fonds S.A. RAIF will not be considering principal adverse impacts on sustainability factors at this time. Although the Fund may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.
Mondriaan Co-Investments SLP - Article 4 Statement
For the ESG/SFDR disclosure please refer to the dedicated webpage here:
Sanne LIS S.A. as alternative investment fund manager of NOAL SCSp (the “Fund”) together with the Investment Adviser of the Fund, BRG ASSET MANAGEMENT LLC, does not consider the principle adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
For the relevant website disclosures related to Ocean 14 Capital Fund 1 SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached file:
For the relevant website disclosures related to P Capital Partners V LUX, SCSP under the Sustainable Finance Disclosure Regulation please refer to the attached file:
Peakside Real Estate Fund IV, SCS is classified as neutral under the EU Sustainable Finance Disclosure Regulation (SFDR) as the fund currently does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments. However, Peakside strives to include ESG factors in its investment decisions and targets a future classification of PREF IV as an Article 8 fund under SFDR.
For the time being the fund does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
For the time being the fund does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
For the Article 4 statement applicable to PRIVATE CAPITAL POOL SICAV-SIF, please refer to the document.
In relation to Art. 7 of SFDR which requires disclosure of how principal adverse impacts are considered at the Fund level, Q Management LP and the Real Estate Advisor note that there are still a number of uncertainties regarding this obligation, in particular because the SFDR regulatory technical standards ("SFDR RTS") have not yet been finalised by the European authorities. Q Management LP and the Real Estate Advisor are currently considering their approach in this area for the Fund, pending the effective date of the final SFDR RTS and will provide further details in due course.
Consideration of principal adverse effects on sustainability factors
This disclosure is being published to comply with the obligation under the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 to disclose sustainability-related information (the “Disclosure Regulation”) relating to principal adverse impacts on sustainability factors (“PAI”).
The regulatory technical standards under the Disclosure Regulation (“SFDR RTS”) specifies the content, methodologies and presentation of such disclosure obligation. Given the publication of the final report on the draft SFDR RTS was delayed from the third quarter of 2020 until February 2021, and the draft remains subject to adoption by the European Commission and scrutiny by the European Parliament and Council, the principal adverse impacts on sustainability factors are currently not considered in relation to the Fund within the meaning of the Disclosure Regulation.
RECAP Opportunity Fund III SCS SICAV-RAIF is not considering principal adverse impacts on sustainability factors at this time. Although the Fund may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.
Currently Round Hill Real Estate Partners SCSp does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Art 4 of the SFDR.
Round Hill takes sustainability and ESG very seriously, however the detailed requirements regarding adverse impacts were not settled by 10 March 2021 when the firm was required to decide and publish the initial approach. Round Hill is continuing to assess the mandatory data collection and disclosure requirements around these.
For further insights on the ESG approach of Round Hill Real Estate Partners SCSp, please see the below ESG Policy.
S.ALT SA SICAV RAIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
SAEV AI SCS, SICAV-RAIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
For the relevant website disclosures related to SC Core Lux Fund SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached files:
For the website disclosure, ESG Policy and PAI statement related to Sequoia Infrastructure Debt Fund, under the Sustainable Finance Disclosure Regulation please refer to the below files:
In relation to Article 4 SFDR, where applicable and relevant, the AIFM will not consider principle adverse impacts of investment decisions on sustainability factors as there is not sufficient guidance in the market relating to it yet but the AIFM will monitor the development going forward, in particular in light of the implementation deadline of 30 December 2022 on such principle adverse impact disclosure.
While Slate Asset Management (Europe) Limited (“Slate”) takes into account sustainability risks in its investment recommendations related to investments made by Slate European Real Estate Fund III’s (the “Fund”), Slate does not currently consider adverse impacts of investment decisions on sustainability factors as defined by the SFDR. Slate has chosen not to do so presently as it considers its existing ESG policies and procedures to be appropriate, proportional and tailored to the investment strategies of the Fund. Slate intends to continually review this position and work towards developing more data over time in order to facilitate such considerations.
All investment decisions in relation to the Fund broadly consider the principal adverse impacts of those decisions on sustainability.
Please refer to the below documentation for further details on the methodologies and approaches:
Smart Markets Luxebourg Fund SCSp - Article 10 Disclosure
Smart Markets Luxebourg Fund SCSp - Article 10 Disclosure - Summary Translations
For the relevant website disclosures related to Storebrand Alternative Investments S.A. SICAV-RAIF, under Sustainable Finance Disclosure Regulation please refer to the policy document below:
Article 10 Disclosure - Storebrand Infrastructure Fund II
Article 10 Disclosure - Summary Translation - Storebrand Infrastructure Fund II
Sustainable Investment Policy - Storebrand Asset Management AS
Article 10 Disclosure - Storebrand Nordic Real Estate Fund
Article 10 Disclosure - Storebrand Infrastructure Fund
Article 10 Disclosure - Cubera Impact Fund I
Article 10 Disclosure - Cubera International Private Equity 22
Article 10 Disclosure - Cubera International Private Equity 23
Article 10 Disclosure - Cubera International Private Equity 24
The below statements are applicable for:
- Tempus Europe Investment Fund Sarl SICAV-SIF
- Tempus Europe Fund III Sarl SICAV SIF
The Fund will not be considering principal adverse impacts on sustainability factors at this time. Although the Fund may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.
The Fund does not consider adverse impacts resulting from its investment decisions with respect to sustainability factors due to the nature of the investments being performed by the Fund (Art. 7 (2) Disclosure Regulation).
The Fund will not be considering principal adverse impacts on sustainability factors at this time. Although the Fund may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.
Trilantic Europe has considered, and continues to consider, ESG factors in its investment process but it does not, at this stage, consider adverse impacts of investment decisions on sustainability factors as specifically contemplated by the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (the “SFDR”). Trilantic Europe has chosen not to do so for the present time as it considers its existing ESG policies and procedures to be appropriate, proportional and tailored to the investment strategy of Trilantic Europe funds. Trilantic Europe continues to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance and will, where required or otherwise appropriate, make changes to its existing policies and procedures.
Article 10 disclosure Trill Impact Intermediary SCSp
Article 10 disclosure Trill Impact (No.1) SCSp
Article 10 disclosure Trill Impact (No.2) SCSp
Article 10 disclosure Trill Impact (No.3) SCSp
Article 10 disclosure Trill Impact Ventures Intermediary SCSp
Article 10 disclosure Trill Impact Ventures (No.1) SCSp
Article 10 disclosure Trill Impact Ventures (No.2) SCSp
Article 10 disclosure Trill Impact II Intermediary SCSp
Article 10 disclosure Trill Impact II (No. 1) SCSp
Article 10 disclosure Trill Impact II (No. 2) SCSp
For the Article 4 statement in place for UBS (Lux) Real Asset Feeder and Master Funds, please refer to the link: <link https: www.ubs.com global en asset-management regulatory.html. _blank external-link-new-window external link in new>
www.ubs.com/global/en/asset-management/regulatory.html.
For the ESG Policy in place for UBS (Lux) Real Asset Feeder and Master Funds, please refer to the link:
For the relevant documents related to Vesper Next Generation Infrastructure Fund I SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached files:
For PAI and Article 10 disclosures of VICENDA Debt Opportunities SCA SICAV-RAIF please refer to the below documents:
Article 10 Disclosure - English
Article 10 Disclosure - German
PAI Reporting:
VKD INVEST SICAV SIF S.C.A. does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
The Fund will not be considering principal adverse impacts on sustainability factors at this time. Although the Fund may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.
The below statement applies to: Wilshire European Venture Capital Fund II SCSp and Wilshire European Venture Capital Fund III SCSp:
Wilshire does not currently consider the adverse impacts of its investment decisions on sustainability factors.
Given the nature of Wilshire’s business generally, Wilshire does not currently consider adverse impacts on Sustainability Factors with respect to any of its products that fall within the Regulation. Given the obligations contained in the Regulations (including the technical methodologies and data capture requirements this would reasonably entail) compliance with the Regulations is not assured among the different portfolio managers that many of the Wilshire products will invest with. As such, there is no assurance that Wilshire will have access to clear, comparable and consistent data with which to report on principal adverse impacts of investment decisions on Sustainability Factors. This decision will, however, be kept under regular review.
The below statement is applicable for ZCH AM SICAV Small Cap Latam Fund, ZCH AM SICAV Latam High Yield Bond Fund and ZCH AM SICAV ESG Latam Fund:
ZCH AM SICAV does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.
