Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”) Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”), which is part of a broader legislative package under the European Commission Action Plan on Financing Sustainable Growth (the “EU Action Plan”) that set out an EU strategy for sustainable finance, will come into effect on 10 March 2021. SFDR requires transparency with regard to the integration of evaluations of sustainability risks and consideration of adverse sustainability impacts of the actions financial products and financial market participants. “Sustainability Risk” means an environmental, social, or governance event or condition that, if it occurs, could potentially or actually cause a material negative impact on the value of a sub-fund’s investment. Sustainability risks 6 6 can either represent a risk of their own or have an impact on other risks and may contribute significantly to risks, such as market risks, operational risks, liquidity risks or counterparty risks. Sustainability Risks may have an impact on long-term risk adjusted returns for investors. Assessment of sustainability risks is complex and may be based on environmental, social, or governance data which is difficult to obtain and incomplete, estimated, out of date or otherwise materially inaccurate. Even when identified, there can be no guarantee that these data will be correctly assessed. Consequent impacts to the occurrence of sustainability risk can be many and varied according to a specific risk, region or asset class. Generally, when sustainability risk occurs for an asset, there will be a negative impact and potentially a total loss of its value and therefore an impact on the net asset value of the concerned Sub-Fund. To meet the SFDR disclosure requirements, the AIFM identifies and analyses Sustainability Risk as part of its risk management process. The AIFM believes that the integration of this risk analysis could help to enhance long-term risk adjusted returns for investors, in accordance with the investment objectives and policies of the Sub-Fund and the AIFM therefore integrates sustainability risks in its investment process. At the date of this Investment Memorandum, it is difficult to predict the full extent of the impact of SFDR and the EU Action Plan on the Fund and its Sub-Funds. The AIFM reserves the right to adopt such arrangement as it deems necessary or desirable to ensure that the Fund and its Sub-Funds complies with any applicable requirements of the SFDR and any other applicable legislation or regulations related to the EU Action Plan. In particular, the AIFM and the Fund await the further consultation and/or guidance on the level 2 regulatory technical standards (the “RTS”), and the finalisation of the RTS. Once published, this Investment Memorandum and/or the websites of the AIFM may be updated to include further disclosures as required. The Fund is not considered an ESG financial product since it does not promote environmental or social characteristics, and do not have as objective sustainable investment (as provided by Articles 8 or 9 of SFDR). However, the Fund may be exposed to sustainability risks due to the nature of the assets in which it invests.
Taxonomy Regulation Disclosures : The investments underlying of the various Funds do not take into account the EU criteria for environmentally sustainable economic activities.
