Regulatory Disclosure

Sustainable Investment Policy

Pursuant to EU Regulation (EU) 2019/2088 of the European Parliament on sustainability-related disclosures in the financial services sector, which is also known as the “Sustainable Finance Disclosure Regulation” (the SFDR), the Company is required to disclose the manner in which sustainability risks are integrated into the investment decision-making process and the results of the assessment of the likely impacts of sustainability risks on the returns of each Sub-Fund.

The Company does not promote, among other characteristics, environmental or social characteristics, or a combination of these characteristics according to Article 8 of SFDR and does not have sustainable investment as its objective according to Article 9 of SFDR.

The Company, therefore, is classified under Article 6 of SFDR, sustainability risks are not explicitly taken into account for the investment decisions being made in respect of each Sub-Fund, based on their investment strategy.

Regarding “Principal adverse impacts”: the Company decides not to currently consider the principal adverse impacts of investment decisions on sustainability factors for each Sub-Fund as defined in Article 7 (2) of the SFDR. As per the current investment strategy and the composition of the portfolio, the Company assesses that such impact is deemed not to be relevant.

Therefore, the Sub-Fund’s underlying investments do not actively take into account the EU criteria for environmentally sustainable economic activities, as provided by Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment.

Investment process

The Sub-Fund’s objective is to provide superior risk-adjusted performance taking into account all relevant issuer-specific practices within the investment process. The investment process, amongst other criteria such as credit risk and country risk, also integrates sustainability risk considerations. The Fund though does not have sustainable investment as its objective nor does it promote, per se, sustainability characteristics. 

The investment process includes the identification, monitoring, and management of sustainable risks as it relates to a company’s operations and its management structure. The analysis of sustainability risk is applied across all sectors and geographies which the Fund may invest. Sustainability risk is analysed at the time of the initial investment and through the ongoing portfolio risk management procedures.  

Sustainability risk factors include:

  • Environment issues such as energy efficiency, waste and pollution.
  • Social issues such as human rights and equal opportunity.
  • Governance issues such as conflicts of interest.

Portfolio investments in companies which exhibit controversial business practices or are deemed to have heightened sustainability risks are closely monitored, re-evaluated, and potentially reduced.