SFDR DIsclosure
1. INTEGRATION OF SUSTAINABILITY RISKS
2. NO CONSIDERATION OF SUSTAINABILITY ADVERSE IMPACTS
Notwithstanding the fact that the Manager considers sustainability risks that could cause an actual or potential material negative impact on the value of an investment, the Manager does not consider the adverse impacts of its investment decisions for the Funds on sustainability factors, within the meaning of Article 4(1)(a) of the SFDR, for the time being. The Manager does not currently do so because the Manager is not, in its view, currently in a position to obtain and/or measure all the data which it would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost with respect to all their investment strategies to clients and investors. This is in part because underlying investments are not widely required to, and may not currently, report by reference to the same data. The Manager’s position on this matter will be reviewed at least annually.
3. REMUNERATION
The Manager’s remuneration policy or other remuneration arrangements relating to its staff takes into account compliance with its policies and procedures related to the integration of sustainability risks in its investment decision-making process.