Regulatory disclosures on ESG matters

In accordance with 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), please find below the relevant website disclosures.

Sanne LIS S.A. ESG Policy


Sanne LIS S.A. AIFM Article 4 Disclosures

Without prejudice to any different and exceptional fund-specific approach or reasoning as specifically agreed with the relevant fund, having embedded the relevant due diligence policies in the relevant investment decisions applicable to those funds as separately disclosed on this website, Sanne LIS S.A. will generally not consider adverse impacts of investment decisions on sustainability factors due to absence of (i) sufficient data/ information and (ii) sufficient quality of such date/information to provide a meaningful assessment on the performance of any potential adverse impact of the investment decisions on sustainability factors in view of the lack of relevant information from target companies/investments.

Fund specific ESG policies and Article 4 statements

  • GreenOak Funds

    GreenOak Funds

    For the Article 4 statement applicable, please refer to the document.

     

    GreenOak Funds

  • GTIS Denver-Boulder Co-Invest SCS

    GTIS Denver-Boulder Co-Invest SCS

    GTIS Denver-Boulder Co-Invest S.C.S. do not currently consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors within the meaning of the SFDR, but may decide to do so following the finalization of the regulatory technical standards under the Disclosure Regulation (“SFDR RTS”), specifying the content, methodologies and presentation of the disclosure that would be required for the consideration of the PAIs of the fund`s investment decisions on sustainability factors, given the application of the SFDR RTS has been delayed until January 2022 and the draft remains subject to adoption by the European Commission and scrutiny by the European Parliament and Council.

  • HF Private Debt Fonds SCSp

    HF Private Debt Fonds SCSp

    HF Private Debt Fonds SCSp does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.

  • H.I.G. Whitehorse Luxembourg Loan Feeder Fund – 2020, SCSp

    H.I.G. Whitehorse Luxembourg Loan Feeder Fund – 2020, SCSp

    The Fund will not be considering principal adverse impacts on sustainability factors at this time. Although the Fund may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.

  • KÖZU Private Markets 17 SICAV RAIF SCA

    KÖZU Private Markets 17 SICAV RAIF SCA

    The fund does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.

  • LIC US Growth Fund SICAV-FIS, SCS

    LIC US Growth Fund SICAV-FIS, SCS

    At this stage, the fund is not considering the principle negative impact of investment decisions on sustainability factors and a change in this approach is currently not intended. Considering the nature and structure of the fund's underlying investments, the collection of the necessary data on the relevant sustainability indicators is as such not possible.

  • Long Harbour Euro Secured Income I

    Long Harbour Euro Secured Income I

    Long Harbour Euro Secured Income I Fund. The Fund’s strategy does not have an ESG focus but investment decisions taken by the portfolio manager does take into consideration environmental and the impact of investment decisions on sustainability factors as detailed in the Fund´s ESG Policy.

     

    Long Harbour Euro Secured Income I

  • MACQUARIE CAPITAL SICAV-RAIF

    MACQUARIE CAPITAL SICAV-RAIF

    The Fund does not consider the principal adverse impacts of investment decisions on sustainability factors and currently does not intend to do so in the future. The nature and structure of the Fund’s underlying investments do not allow it to collect the necessary data on the relevant sustainability indicators.

     

    MACQUARIE CAPITAL SICAV-RAIF

  • M-Alternative Investment Fund (S.C.A.) SICAV-SIF

    M-Alternative Investment Fund (S.C.A.) SICAV-SIF

    M-Alternative Investment Fund (S.C.A.) SICAV-SIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.

  • Madison International Real Estate Liquidity Fund VI, SCS

    Madison International Real Estate Liquidity Fund VI, SCS

    For the Article 4 statement applicable all MADISON INTERNATIONAL REAL ESTATE LIQUIDITY FUND VI, SCS, please refer to the document.

     

    Madison International Real Estate Liquidity Fund VI, SCS

  • New Yellow River Fund, SCSP

    New Yellow River Fund, SCSP

    For the Article 4 statement applicable to NEW YELLOW RIVER FUND, SCSP, please refer to the document.

     

    New Yellow River Fund, SCSP

  • Oakley Capital

    Oakley Capital

    Oakley considers sustainability risks and factors during the investment process, as outlined in the Responsible Investment Policy. Oakley engages with portfolio companies to understand and monitor sustainability factors. Such factors are not currently assessed as prescribed by the draft Regulatory Technical Standards (RTS) of the Sustainable Finance Disclosure Regulation (SFDR) as Oakley uses sustainability KPIs which are material within our portfolio. However, Oakley is monitoring the development and finalization of the RTS and is committed to reviewing its position on a regular basis.<link file:821 - download "Initiates file download"></link>

     

    Oakley Capital ESG Policy

  • OMERS Lux Investment Fund S.à r.l., SICAV-RAIF

    OMERS Lux Investment Fund S.à r.l., SICAV-RAIF

    OMERS Lux Investment Fund S.à r.l., SICAV-RAIF does consider the impact on sustainability factors as part of its investment process, as detailed in the ESG Assesment Procedure.

     

    OMERS Lux Investment Fund S.à r.l., SICAV-RAIF

  • Peakside Real Estate Fund IV, SCS

    Peakside Real Estate Fund IV, SCS

    Peakside Real Estate Fund IV, SCS is classified as neutral under the EU Sustainable Finance Disclosure Regulation (SFDR) as the fund currently does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments. However, Peakside strives to include ESG factors in its investment decisions and targets a future classification of PREF IV as an Article 8 fund under SFDR.

  • Pension Alternative Markets SCS SICAV-FIS

    Pension Alternative Markets SCS SICAV-FIS

    For the time being the fund does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.

  • Polish Enterprise Funds SCA

    Polish Enterprise Funds SCA

    Enterprise Investors (“EI”) deal teams review every investment opportunity from the perspective of its compliance with the EI’s ESG standards which incorporate an elaborate list of sustainability factors. As a matter of principle, deal teams include conclusions from the ESG compliance review memos (dedicated document) in their investment memorandums. They include an overview of the company’s ESG profile and ESG governance, and an overview of the three main ESG areas i.e. environmental, social and governance. Areas of non-compliance are highlighted, together with specific measures for addressing them following EI’s investment. If ESG-related issues are identified earlier in the investment development process, deal teams provide an update on these findings at the earliest opportunity when the deal is discussed by the investment team. EI may invest in an ESG non-compliant business if an immediate opportunity to improve in this respect through EI’s investment is identified. If the identified issues represent material breaches of ESG standards (as would be the case of an investment which directly results in PAI) and cannot be addressed soon after EI’s investment, this should be treated as a major reason for dropping the investment opportunity.

  • PRIMUS Investments S.C.S. SICAV-SIF

    PRIMUS Investments S.C.S. SICAV-SIF

    For the time being the fund does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.

  • Private Capital Pool SICAV-SIF

    Private Capital Pool SICAV-SIF

    For the Article 4 statement applicable to PRIVATE CAPITAL POOL SICAV-SIF, please refer to the document.

     

    Private Capital Pool SICAV-SIF

  • QRES Funds

    QRES Funds

    n relation to Art. 7 of SFDR which requires disclosure of how principal adverse impacts are considered at the Fund level, Q Management LP and the Real Estate Advisor note that there are still a number of uncertainties regarding this obligation, in particular because the SFDR regulatory technical standards ("SFDR RTS") have not yet been finalised by the European authorities. Q Management LP and the Real Estate Advisor are currently considering their approach in this area for the Fund, pending the effective date of the final SFDR RTS and will provide further details in due course.

  • Rantum Private Equity Fund II, SCS

    Rantum Private Equity Fund II, SCS

    Consideration of principal adverse effects on sustainability factors

     

    This disclosure is being published to comply with the obligation under the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 to disclose sustainability-related information (the “Disclosure Regulation”) relating to principal adverse impacts on sustainability factors (“PAI”).

     

    The regulatory technical standards under the Disclosure Regulation (“SFDR RTS”) specifies the content, methodologies and presentation of such disclosure obligation. Given the publication of the final report on the draft SFDR RTS was delayed from the third quarter of 2020 until February 2021, and the draft remains subject to adoption by the European Commission and scrutiny by the European Parliament and Council, the principal adverse impacts on sustainability factors are currently not considered in relation to the Fund within the meaning of the Disclosure Regulation. Rantum may decide to consider PAI in relation to the Fund following the finalisation of the SFDR RTS.

  • Round Hill Real Estate Partners SCSp

    Round Hill Real Estate Partners SCSp

    Currently Round Hill Real Estate Partners SCSp does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Art 4 of the SFDR.

     

    Round Hill takes sustainability and ESG very seriously, however the detailed requirements regarding adverse impacts were not settled by 10 March 2021 when the firm was required to decide and publish the initial approach. Round Hill is continuing to assess the mandatory data collection and disclosure requirements around these.

    For further insights on the ESG approach of Round Hill Real Estate Partners SCSp, please see the below ESG Policy.

    Round Hill Estate Partners SCSp - ESG policy

  • S.ALT SA SICAV RAIF

    S.ALT SA SICAV RAIF

    S.ALT SA SICAV RAIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.

  • SAEV AI SCS

    SAEV AI SCS

    SAEV AI SCS, SICAV-RAIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.

  • Sirius Fund III SCSP

    Sirius Fund III SCSP

    In relation to Article 4 SFDR, where applicable and relevant, the AIFM will not consider principle adverse impacts of investment decisions on sustainability factors as there is not sufficient guidance in the market relating to it yet but the AIFM will monitor the development going forward, in particular in light of the implementation deadline of 30 December 2022 on such principle adverse impact disclosure.

  • Slate European Real Estate Fund III

    Slate European Real Estate Fund III

    Slate does not, within the meaning of Article 4(1)(b) and 4(5)(b) of the SFDR, consider the adverse impacts of its investment decisions on sustainability factors. Slate does not currently do so because, among other reasons, the Regulatory Technical Standards which set forth the final “principal adverse impacts” and the corresponding mandatory reporting template have not yet been adopted by European legislators, which is expected to limit the availability of investment-level data required for voluntary compliance with Article 4(1)(a) and 4(5)(a). Slate intends to continually review this position and work towards developing more data over time in order to facilitate such considerations.

  • SMART MARKETS LUXEMBOURG FUND SCSP

    SMART MARKETS LUXEMBOURG FUND SCSP

    For the Article 4 statement applicable to Smart Markets Luxembourg Fund SCSp, please refer to the below document.

     

    Stockbridge Environmental Social Responsibility and Governance.

  • Streetlane SCS

    Streetlane SCS

    Streetlane S.C.S. do not currently consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors within the meaning of the SFDR, but may decide to do so following the finalization of the regulatory technical standards under the Disclosure Regulation (“SFDR RTS”), specifying the content, methodologies and presentation of the disclosure that would be required for the consideration of the PAIs of the fund`s investment decisions on sustainability factors, given the application of the SFDR RTS has been delayed until January 2022 and the draft remains subject to adoption by the European Commission and scrutiny by the European Parliament and Council.

  • Tempus Europe Investment Fund Sàrl SICAV-SIF

    Tempus Europe Investment Fund Sàrl SICAV-SIF

    The Fund will not be considering principal adverse impacts on sustainability factors at this time. Although the Fund may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.

  • The Realty Associates Fund XI SCS

    The Realty Associates Fund XI SCS

    The Fund does not consider adverse impacts resulting from its investment decisions with respect to sustainability factors due to the nature of the investments being performed by the Fund (Art. 7 (2) Disclosure Regulation).

  • Trilantic Europe VI SCSp

    Trilantic Europe VI SCSp

    Trilantic Europe has considered, and continues to consider, ESG factors in its investment process but it does not, at this stage, consider adverse impacts of investment decisions on sustainability factors as specifically contemplated by the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (the “SFDR”). Trilantic Europe has chosen not to do so for the present time as it considers its existing ESG policies and procedures to be appropriate, proportional and tailored to the investment strategy of Trilantic Europe funds. Trilantic Europe continues to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance and will, where required or otherwise appropriate, make changes to its existing policies and procedures.

     

    Trilantic Europe VI SCSp

  • UBS (Lux) Real Asset Feeder & Master Funds

    UBS (Lux) Real Asset Feeder & Master Funds

    For the Article 4 statement in place for UBS (Lux) Real Asset Feeder and Master Funds, please refer to the link: <link www.ubs.com/global/en/asset-management/regulatory.html. _blank external-link-new-window "Opens external link in new window">https://www.ubs.com/global/en/asset-management/regulatory.html. </link>

    For the ESG Policy in place for UBS (Lux) Real Asset Feeder and Master Funds, please refer to the link:

    <link www.ubs.com/global/en/asset-management/regulatory.html. _blank external-link-new-window "Opens external link in new window">https://www.ubs.com/global/en/asset-management/regulatory.html </link>

  • US Government Building Open-End (EU Parallel 1 and 2) SCS

    US Government Building Open-End (EU Parallel 1 and 2) SCS

    US Government Building Open-End (EU Parallel 1 and 2) SCS

  • USAA Eagle Real Estate (EU Parallel) SCS

    USAA Eagle Real Estate (EU Parallel) SCS

    As (on a product/fund-level) it is not necessary to consider and disclose the PAI until 30 December 2022, USAA`s intention is to wait until the finalization of the RTS for further clarity and/or guidance on this.

  • VKD Invest SICAV-SIF SCA

    VKD Invest SICAV-SIF SCA

    VKD INVEST SICAV SIF S.C.A. does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors as well as due to lack of relevant disclosures from target investments.

  • WH HECP QCM SCSp

    WH HECP QCM SCSp

    The Fund will not be considering principal adverse impacts on sustainability factors at this time. Although the Fund may consider sustainability as part of its investment processes, the uncertainty about the level of information required to be gathered and the level of assessment required to carry out the exercise mean that this is not considered feasible at this time.

  • ZCH AM SICAV

    ZCH AM SICAV

    The below statement is applicable to Small Cap Latam Fund as well as Latam High Yield Bond Fund:

    Once the investment decision is made and executed (buy/sell, over/underweight/no position), there is a continuous ongoing monitoring process, where financial theses are continuously revised based on company releases, management discussion, additional research pieces, news flow, regulatory changes among other variables that could impact short terms and long term performance and sustainability of the investment. "

    The incorporation of Environmental, Social and Governance (ESG) factors into the investment process is a key element of the UN Principles for Responsible Investments (PRI), which the Group signed up to in 2012. These factors are assessed alongside more traditional financial metrics by ZCH AM SICAV portfolio managers. In this sense, ZCH AM SICAV has access to specific data, training and proprietary analysis to enhance and strengthen its investment decision process. Given the evolving nature of ESG, these data sources may for the time being be incomplete, inaccurate or unavailable, and involve a significant element of subjectivity. Neither the Company, the Management Company nor the Investment Manager make any representation or warranty, express or implied, with respect to the fairness, correctness, accuracy or completeness of such ESG assessment.


Article 8 Funds Disclosures

  • [Translate to Deutsch:] AltaCAM Global Credit II SC SICAV-RAIF

    [Translate to Deutsch:] AltaCAM Global Credit II SC SICAV-RAIF

    [Translate to Deutsch:]

    Luxembourg Investment Solutions S.A. and the Investments Advisers of AltaCAM Global Credit II SCA SICAV- RAIF, do not consider nowadays adverse impacts of investment decisions on sustainability factors. Managers that consider adverse sustainability impacts shall publish, on annually basis, the indicators established in Annex I of the Draft Regulatory Technical Standards (RTS). The nature of AltaCAM Global Credit II SCA SICAV- RAIF (a fund of funds) imply that to consider adverse sustainability impacts, Luxembourg Investment Solutions S.A. and the Investments Advisers of the Fund should receive from the managers of the underlying funds the mandatory information in order to comply with the regulation.

     

    When the European Commission approves the RTS and the actual lack of regulatory certainty disappears, Luxembourg Investment Solutions S.A. and the Investments Advisers of the Fund will make their best efforts to obtain the mandatory information and, then, consider the adverse impacts of investment decisions on sustainability factors. [1] Sustainability adverse impacts: negative material or likely to be material effects on sustainability factors that investment decisions and advice might cause, contribute to or be directly linked to.

    AltaCAM Global Credit II SC SICAV-RAIF

  • [Translate to Deutsch:] CAM Alternatives

    [Translate to Deutsch:] CAM Alternatives

    [Translate to Deutsch:]

    The below statement applies to CAM Infrastructure Strategies, S.C.S. SICAV-RAIF , CAM Private Capital Strategies, S.C.A. SICAV-RAIF , CAM Private Equity Strategies, S.C.S. SICAV-RAIF:

    For further details on the below, please refer to the specific ESG Policy:

    The fund takes into account principal adverse impacts on sustainability factors. In order to identify and avoid adverse sustainability impacts through its investments, the fund applies a multi-level risk management approach. The ESG risk analysis and assessment of the target fund manager (through dialogue with the manager and ESG assessment of the product family) and of the underlying portfolio (industry/sector analysis, country analysis, analysis of historical ESG events) build the core risk management approach. The ESG risk assessment and the results of an evaluation in a specially developed ESG scoring model are documented in the investment memorandum and thus support a balanced assessment of the risk-return profile of the specific investment opportunity.

    For further details on the below, please refer to the specific ESG Policy. The fund takes into account principal adverse impacts on sustainability factors. In order to identify and avoid adverse sustainability impacts through its investments, the fund applies a multi-level risk management approach. The ESG risk analysis and assessment of the target fund manager (through dialogue with the manager and ESG assessment of the product family) and of the underlying portfolio (industry/sector analysis, country analysis, analysis of historical ESG events) build the core risk management approach. The ESG risk assessment and the results of an evaluation in a specially developed ESG scoring model are documented in the investment memorandum and thus support a balanced assessment of the risk-return profile of the specific investment opportunity.

    CAM Alternatives ESG Policy

  • [Translate to Deutsch:] SC CORE LUX FUND SCSP

    [Translate to Deutsch:] SC CORE LUX FUND SCSP

    [Translate to Deutsch:]

    SC CORE LUX FUND SCSP - ESG Policy

    SC CORE LUX FUND SCSP - Article 10 Statement
     

  • [Translate to Deutsch:] VB Private Equity SCS-RAIF

    [Translate to Deutsch:] VB Private Equity SCS-RAIF

    [Translate to Deutsch:]

    The fund takes into account principal adverse impacts on sustainability factors. In order to identify and avoid adverse sustainability impacts through its investments, the fund applies a multi-level risk management approach. The ESG risk analysis and assessment of the target fund manager (through dialogue with the manager and ESG assessment of the product family) and of the underlying portfolio (industry/sector analysis, country analysis, analysis of historical ESG events) build the core risk management approach. The ESG risk assessment and the results of an evaluation in a specially developed ESG scoring model are documented in the investment memorandum and thus support a balanced assessment of the risk-return profile of the specific investment opportunity.

    VB Private Equity SCS-RAIF

  • [Translate to Deutsch:] ZCH AM SICAV - Latam Fund

    [Translate to Deutsch:] ZCH AM SICAV - Latam Fund

    [Translate to Deutsch:]

    The ZCH AM SICAV ESG Latam Fund’s objective is to offer a competitive alternative to invest in the Latin American Equity market through those companies that outperform their peers in terms of relevant ESG factors identified for their industry. As such, the strategy allows investors to access different sectors within the investment universe while reducing potential negative impacts related to controversies and mismanagement of environmental, social and governance variables. This strategy is combined with the traditional financial approach, aiming to maximize value for investors by selecting those companies with higher upside potential among those that already meet the ESG leadership criteria within their industry, in those industries with attractive dynamics.

    As part of our ESG integration methodology, analysis is conducted on an industry basis in order to identify E, S and G related risks and opportunities that are relevant for each sector beyond general definition of ESG factors. As such, the objective is to create a materiality framework, which will not only identify those factors but also will aim to assess its relevance in time: short term and long term potential impacts for the industry as a whole.

    ZCH AM SICAV - Latam Fund ESG Policy

    Summary of information for Latin America


Article 9 Funds disclosures

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