Sustainability-related disclosures

The SFDR lays down harmonised rules for financial market participants on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes and the provision of sustainability‐related information with respect to financial products.

In accordance with these rules, the AIFM is required to disclose how sustainability risks are integrated into the investment decision and the results of the assessment of the likely impacts of sustainability risks on the Fund’s returns. The AIFM is considered to fall within the scope of Article 6 of the SFDR. Indeed, it does not promote environmental or social characteristics and does not pursue a specific sustainable investments objective.

Consequently, sustainability risks are not integrated into the investment decisions or in the risk monitoring and are deemed not to be relevant, as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis has no impact on the potential reduction of sustainability risks that the investment strategy of the AIFM may generate.

The AIFM shall continue to review and consider its obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.

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