Sustainability Disclosures

The fund manager integrates sustainability risks into its investment decision-making processes on a proportionate basis, taking into account the nature, scale and complexity of its activities. Sustainability risks are considered as part of the overall investment risk assessment, in particular where such risks are relevant to the value and performance of the underlying assets. Given the targeted investment strategy and limited scope of the portfolio managed, sustainability risks are assessed primarily at the level of individual investment opportunities and are addressed through general due diligence and risk management processes, without the application of a dedicated or systematic ESG framework. The fund manager considers that this approach is appropriate and proportionate to its size, organisational structure and investment activities.

The fund manager has assessed that, at the current stage, the implementation of a comprehensive framework for identifying, measuring and monitoring principal adverse impacts in accordance with the detailed regulatory technical standards would require disproportionate operational resources and data dependencies, which would not be commensurate with the scale and characteristics of its activities. The fund manager does not commit to a specific date for considering principal adverse impacts, but this position remains subject to review.

The funds managed do not promote environmental or social characteristics and do not have sustainable investment as their objective (Article 6 SFDR). The investments underlying these financial products do not take into account the EU criteria for environmentally sustainable economic activities.