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Regulatory Information

SFDR Article 6

Sustainability Risk Disclosure

EU Regulation 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector

Sustainability risks are defined as environmental, social or governance events or conditions that the General Partner considers could have a principal adverse impact on the value of one or more investments in the Fund in accordance with SFDR.

The Fund currently does not promote environmental or social characteristics, nor does it have sustainable investment as its objective within the meaning of Articles 8 or 9 of SFDR.

The General Partner integrates sustainability risks into its investment decision-making process to the extent considered relevant and proportionate to the investment strategy and asset class of the Fund. This integration is carried out on a best-efforts basis and does not constitute a binding commitment to apply any ESG screening, exclusion policy or minimum sustainability threshold.

The General Partner's approach to sustainability risk integration includes, as applicable:

  • identification of ESG-related risk factors that may be material to the Fund's investment universe during the due diligence process prior to investment;
  • qualitative assessment of environmental risks (e.g., climate-related transition or physical risks), social risks (e.g., labour standards, supply chain risks) and governance risks (e.g., management quality, ownership structure, anti-corruption practices) where relevant data is available and deemed reliable;
  • ongoing monitoring of portfolio investments to identify emerging sustainability risks that could adversely affect valuations;
  • consideration of sustainability risk factors as part of the GP's overall risk management framework, alongside financial, legal, operational and other risks.

The degree to which sustainability risks are incorporated into individual investment decisions may vary depending on the availability and quality of data, the nature of the underlying asset and the stage of the investment process. The General Partner does not apply a systematic or quantitative ESG scoring methodology at this stage.

The General Partner has assessed the likely impact of sustainability risks on the returns of the Fund. Based on this assessment, the General Partner considers that sustainability risks are likely to have a variable impact on the financial returns of the Fund.

The General Partner notes that sustainability risks, by their nature, are difficult to quantify and that the above assessment is based on qualitative analysis and currently available information. Such assessment is subject to revision as analytical frameworks, data availability and regulatory guidance evolve.

No Consideration of Sustainability Adverse Impacts

The Fund currently does not consider the adverse impact of its investment decisions on sustainability factors considering:

  • The General Partner is a registered sub-threshold AIFM and does not meet the threshold of 500 employees set out in Article 4(3) of SFDR that would trigger a mandatory obligation to consider and report on PAIs at entity level.
  • The General Partner is of the view that, given the current stage of development of its ESG data infrastructure and the nature and scale of its investment activities, the cost and operational burden of collecting and reporting PAI data would be disproportionate to the information value provided to investors.