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Sustainable Finance Disclosure Regulation (SFDR)

The Company and each sub-fund (together the “Funds”) are classified as Article 6 financial products for the purposes of Regulation (EU) 2019/2088 on sustainability‑related disclosures in the financial services sector (“SFDR”).

The Funds do not promote environmental or social characteristics within the meaning of Article 8 of SFDR, nor do they have sustainable investment as their objective within the meaning of Article 9 of SFDR.

Sustainability Risk Considerations

In accordance with Article 6 of SFDR, the AIFM is required to disclose how sustainability risks are integrated into its investment decisions and the results of its assessment of the likely impacts of such risks on the returns of the Funds. Where sustainability risks are not considered relevant, the AIFM is required to provide clear and concise reasons for that assessment.

The AIFM has assessed the relevance of sustainability risks to the Funds as part of its overall investment and risk management framework. Based on the Funds’ investment strategy and structure, the AIFM considers that sustainability risks are not relevant for the Funds in a manner that is expected to have a material impact on the returns of the Funds.

This assessment is based on the nature of the Funds’ investment strategy, under which the Funds obtain exposure primarily through investments in third-party managed collective investment schemes (“Underlying Funds”), and on the AIFM’s assessment that sustainability risks at the level of any individual underlying investment are not expected to have a material direct impact on the Funds’ overall returns. Further, the AIFM does not select underlying funds by reference to sustainability objectives, environmental or social characteristics, EU Taxonomy alignment or minimum ESG criteria.

Sustainability risks may nevertheless exist at the level of the Underlying Funds or their underlying portfolio investments, and such risks may be relevant to the returns of those Underlying Funds. The AIFM’s assessment is that, given the Funds’ indirect investment structure and the absence of direct portfolio asset selection by the AIFM, such risks are not expected to have a material direct impact on the returns of the Funds.

The assessment represents the AIFM’s current view and is reviewed periodically as part of the AIFM’s internal control framework.

Investment Strategy and Underlying Funds

The Funds pursue their investment objective primarily by investing globally in third‑party collective investment schemes. These Underlying Funds may be established in various jurisdictions and may be managed by investment managers that are not subject to SFDR or equivalent sustainability disclosure regimes. Accordingly:

  • The Underlying Funds are not required to be classified under Article 6, Article 8 or Article 9 of SFDR.
  • The Funds do not require that Underlying Funds integrate sustainability risks, promote environmental or social characteristics, or pursue sustainable investment objectives.
  • The Funds do not apply any minimum ESG criteria or sustainability‑related exclusions at the level of Underlying Funds.

As a consequence, the Funds cannot ensure consistency between their own SFDR classification and the sustainability‑related practices or disclosures (if any) of the Underlying Funds.

Look‑Through and Data Limitations

Due to the Funds’ reliance on third‑party managers and the absence of harmonised sustainability disclosures across all jurisdictions and investment structures in which the Underlying Funds may operate, comprehensive, comparable and reliable sustainability‑related data at the Underlying Fund level may not be available. The AIFM therefore does not commit to:

  • conducting look‑through SFDR classification of Underlying Funds,
  • calculating alignment with the EU Taxonomy Regulation, or
  • considering principal adverse impacts on sustainability factors under Article 4 of SFDR.

No Sustainable Investment Objective

The Funds do not make sustainable investments as defined under Article 2(17) of SFDR and do not take into account the EU criteria for environmentally sustainable economic activities under Regulation (EU) 2020/852 (the “EU Taxonomy Regulation”). The Funds’ investments are therefore not assessed for EU Taxonomy alignment.