SFDR Policy
This SFDR Policy reflects the AIFM’s integration of sustainability risks in the investment decision-making process.
Sustainability Risk
The Sub-Funds do not have as their objective sustainable investment, nor do they promote environmental or social characteristics. As a result, the Sub-Funds do not fall within the scope of Regulation (EU) 2020/852 of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investment. This means that the investments underlying these Sub-Funds do not take into account the EU criteria for environmentally sustainable economic activities. The Sub-Funds do not promote, among other characteristics, environmental or social characteristics, or a combination of those characteristics according to Article 8 of SFDR and do not have sustainable investment as their objective according to Article 9 of SFDR.
Pursuant to Article 3 of the Sustainable Finance Disclosure Regulations (EU) 2019/2088 (the ‘SFDR’), it is required to disclose the extent to which sustainability risks are integrated into the investment decision making process.
Integration of sustainability risks
The AIFM accounts for sustainability risks within its investment decision making process.
Sustainability factors means environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. Environmental factors may include, but are not limited to, the impact of emissions, energy efficiency, the exploitation of natural resources or waste treatment. Social factors may include human rights, treatment of workers and workers’ rights or diversity issues. Governance factors may include shareholder rights, remuneration of senior management, conflicts of interest or board independence.
The sustainability risks relating to securities within the investment universe of the Sub-Funds are measured through consideration of the disclosures in issuers’ annual reports and through interacting with the relevant fund managers and other third parties that may be relevant for the underwriting of said sustainability risks.
Investment decisions are based on a due diligence process including a wide range of factors, analyzing sustainability factors, business models, competitive environment, company financials and management incentives. Determining the sustainability risks can affect all known types of risk (for example, market risk, liquidity risk, counterparty risk and operational risk), and as a factor contribute to the materiality of these risk types. When based on this due diligence, sustainability risks are identified that could lead to a risk of loss of return, these risks will be taken into account in conjunction with the analysis of other relevant factors so that a balanced approach can be taken with regards to the merits of investing in the relevant security.
The AIFM acknowledges that the Sub-Funds' exposure to sustainability risks is a dynamic process in the current environment and shall subject the Sub-Funds’ exposure to these risks to periodic review.
Principle Adverse Impacts
It is anticipated that the occurrence of the sustainability risks stated above could have an impact on the financial returns of the Sub-Funds.
The assessment of sustainability risks is complex and often requires subjective judgements, which may be based on data, which is difficult to obtain, incomplete, estimated or otherwise materially inaccurate. Even when identified, there can be no guarantee that the impact of sustainability risks on an investment will be correctly assessed.
Therefore, the AIFM does not currently consider the principal adverse impacts of their investment decisions on sustainability factors.
The adverse impact of investment decisions on sustainability factors may be considered in the future when there is reliable information readily available. This matter will be kept under ongoing review and processes may be developed in this regard to the extent permitted by the investment policy of each fund as more comprehensive data on the various sustainability factors becomes available and further guidance is published.
Remuneration policy
Alt Investments confirms that its remuneration policy is consistent with the integration of sustainability risks and does not seek to encourage or reward the assumption of excessive sustainability risks relating to environmental, social or governance issues