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

  • Alinda Infrastructure Funds III and IV

    Alinda Infrastructure Funds III and IV

    The Sponsor does not currently consider the adverse impacts of its investment decisions on sustainability factors, within the meaning of Article 4(1)(a) of the SFDR. The Sponsor does not currently do so because, among other reasons, the draft Regulatory Technical Standards which set forth the scope of “principal adverse impacts” and the corresponding mandatory reporting template are not yet final, which makes voluntary compliance with Article 4(1)(a) challenging. The Sponsor’s position on this matter will be reviewed at least annually.

  • Allianz Debt Fund FPS

    Allianz Debt Fund FPS

    In accordance with SFDR, the Fund shall include in this Offering Memorandum, in relation to each Sub-fund, a description of the manner in which Sustainability Risks are integrated into their investment decisions and the results of the assessment of the likely impacts of Sustainability Risks on the returns of the financial products they make available.

    Allianz Debt Fund FPS

  • Allianz Debt Investments SCSp SICAV-SIF (PIMCO)

    Allianz Debt Investments SCSp SICAV-SIF (PIMCO)

    The Sub-Fund and the appointed Portfolio Manager define integration of environmental, social and governance characteristics (ESG) as the consistent consideration of material Sustainability Risks into the investment research process to enhance the investors' risk-adjusted returns.

    Allianz_Debt Investments SCSp SICAV-SIF (PIMCO)

  • Apax funds

    Apax funds

    The below statements are applicable for:

    • Apax X EUR SCSp
    • Apax XI
    • Apax XI USD

    Currently the fund does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Art 4 of the SFDR.  The Firm takes sustainability and ESG very seriously, however the detailed requirements regarding adverse impacts and the mandatory data collection and disclosure requirements around these remain under review, particularly in light of the revised implementation deadline of 30 December 2022. 

    • Apera Private Debt Funds I and II

      Apera Private Debt Funds I and II

      The below is applicable to Apera Private Debt Fund I SCSp and Apera Private Debt Fund II SCSp : Apera Asset Management GmbH is required to publish information on whether it considers the “adverse impacts of investment decisions on sustainability factors” (the “Principal Adverse Impacts”) under the SFDR. Apera Asset Management GmbH does not currently consider the Principal Adverse Impacts of investment decisions on sustainability factors in connection with its products and services. This is because Apera Asset Management GmbH is not currently in a position to obtain and/or measure all the data that it would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost. This is in part because underlying investments are not widely required to, and may not currently, report by reference to the same data. Date of publication: 10 March 2021.

      Apera Private Debt Funds I and II Policy

       

    • A/O Built Technologies II SCSp

      A/O Built Technologies II SCSp

      A/O expects to mitigate, where possible, the negative impact of investment decisions on factors such as environmental, social and employee matters, human rights, corruption and bribery matters. Currently A/O Built Technologies II SCSp does not assess Principal Adverse Impacts of investment decisions as specifically prescribed under SFDR (Sustainable Finance Disclosure Regulation), as our assessment conforms to our own ESG policy and internal methodology applicable to our portfolio. A/O is monitoring the development SFDR regulation and is committed to reviewing its position on a regular basis.

      A/O Built Technologies II SCSp ESG Policy.

       

    • Best Value Europe II FCP RAIF

      Best Value Europe II FCP RAIF

      Best Value Europe II FCP RAIF

    • BentallGreenOak Luxembourg Funds SCSp, SICAV-FIAR

      BentallGreenOak Luxembourg Funds SCSp, SICAV-FIAR

      BentallGreenOak Luxembourg Funds SCSp, SICAV-FIAR - Article 4 statement

    • Beka Investments SICAV-RAIF SCA

      Beka Investments SICAV-RAIF SCA

      Beka Investments 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. 

    • BID Equity Fund II A and B

      BID Equity Fund II A and B

      Pursuant to the Limited Partnership Agreements (LPA) BID Equity Fund II A and B investment objective is to build, hold and manage a portfolio of equity investments in software companies primarily based in the DACH region (Germany, Austria and Switzerland). BID Equity Fund II A and B do neither incorporate any ESG principles in its investment strategy, nor do the funds promote any environmental or social characteristics or a combination of these. Investing in small-cap B2B software companies mainly in the DACH region, where also the vast majority of portfolio companies’ customers operates their businesses, there is no link to typical ESG issues regarding the funds´ portfolio companies’ business models. Therefore BID Equity Funds I and II will not consider any principle adverse impacts on sustainability factors in the investment decisions.

    • Boston Capital Income and Value U.S. Apartment Funds

      Boston Capital Income and Value U.S. Apartment Funds

      The below statement applies to:

      • Boston Capital Income and Value U.S. Apartment Fund SICAV-SIF
      • Boston Capital Income and Value U.S. Apartment Fund II- A and B

      The Funds will not be considering principal adverse impacts on sustainability factors at this time. Although the Funds 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 subject to ongoing review as we further develop our processes in this respect.

    • BMW i Ventures SCS SICAV RAIF

      BMW i Ventures SCS SICAV RAIF

      BMW i Ventures 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.

    • Caerus Real Estate Debt Lux. S.C.A., SICAV-SIF

      Caerus Real Estate Debt Lux. S.C.A., 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. The fund will review such process until the end of 2021 in order to evaluate the assessment of potential adverse impacts.

    • China Central and Eastern Europe Investment Co-Operation Fund I and II

      China Central and Eastern Europe Investment Co-Operation Fund I and II

      China Central and Eastern Europe Investment Co-Operation Fund SCS SICAV-SIF and China Central and Eastern Europe Investment Co-Operation Fund II SCS SICAV-SIF 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.

    • COLLER INTERNATIONAL PARTNERS VII and VIII

    • Creditshelf Loan Fund S.C.S. SICAV-RAIF

      Creditshelf Loan Fund S.C.S. SICAV-RAIF

      Creditshelf Loan Fund S.C.S. 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.

    • Deerpath Capital SLP-RAIF

      Deerpath Capital SLP-RAIF

      AIFMs need to disclose where they consider principal adverse impacts of investment decisions on sustainability factors. For the time being, except as may be otherwise disclosed at a later stage on its website, The AIFM together with the Investment Manager do not consider adverse impacts of investment decisions on sustainability factors in relation to the Fund. The main reason is actually the lack of information and data available to adequately assess such principal adverse impacts.

      Deerpath Capital SLP-RAIF

    • DESCOPEDIA SCA, SICAV-SIF

      DESCOPEDIA SCA, SICAV-SIF

      The below statement refers both to DESCOPEDIA SELECT STRATEGIES as well as DESCOPEDIA ASIA: The AIFM does not consider the adverse impacts of investment decisions on Sustainability Factors, (i) as no sufficient data of satisfactory quality is available to allow the AIFM to adequately assess the potential adverse impact of the investment decision on Sustainability Factors, (ii) because of a lack of relevant disclosures from target investments and (iii) as there are no adequate methodologies to calculate the potential adverse impact of the investment decision on Sustainability Factors.

    • DF Deutsche Finance 711 Investment Funds

      DF Deutsche Finance 711 Investment Funds

      The below statement refers to DF Deutsche Finance 711 Investment S.C.S. , DF Deutsche Finance 711 Investment III S.C.S. , DF Deutsche Finance 711 Investment II S.C.S: The fund do 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.

    • DR Sachwerte SCS, SICAV-RAIF and VB Sachwerte SCS, SICAV-RAIF

      DR Sachwerte SCS, SICAV-RAIF and VB Sachwerte SCS, SICAV-RAIF

      Neither DR Sachwerte SCS, SICAV-RAIF, nor VB Sachwerte SCS, SICAV-RAIF 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.

    • Energy Transition Investments S.C.A. SICAV-RAIF

      Energy Transition Investments S.C.A. SICAV-RAIF

      The Fund considers the main material or potentially material adverse impacts (“PAIs”) of the Fund's Investments on sustainability factors. These are identified during the due diligence phase of the Investments of the Fund and their evolution is continuously monitored during the ownership phase. Ultimately, the Fund will pursue a reduction of negative externalities caused by the Investments. The due diligence process will adhere to responsible business conduct codes and internationally recognised standards for due diligence and reporting, such as the due diligence for responsible business conduct developed by the OECD and will be aligned with the Paris Agreement’s main goal to make finance flow towards low-carbon technologies and ultimately pursue efforts to limit the temperature increase to 1.5 degrees Celsius above pre-industrial levels. 

      The indicators used to measure the main adverse impacts will be in line with EU regulations, more specifically with the environmental (GHG emissions, water and waste management) and social (board gender diversity, gender pay gap, etc.) indicators included in the regulatory technical standards of the SFDR (“RTS”). These indicators may be subject to customization based on the specific characteristics of each target and Portfolio Company and could be eventually updated in line with the evolving applicable EU legislation and the international best practices in this context. Information on the PAIs on sustainability factors will be integrated into the periodic information that investors will receive and will be reported to them before June 30, 2023 (and thereafter each year before June 30 of the following years) in line with the RTS. 

      Energy Transition Investments S.C.A. SICAV-RAIF ESG Policy
      Energy Transition Investments S.C.A. SICAV-RAIF Disclosures

    • Egeria Master S.C.A. SICAV-RAIF

      Egeria Master S.C.A. SICAV-RAIF

      PAI statement Egeria: 
      Egeria Master SCA, SICAV-RAIF  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”). Egeria Master SCA, SICAV-RAIF 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 its funds. Egeria Master SCA, SICAV-RAIF 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.

    • Enterprising finance the Netherlands Unitranche Fund SCSp

      Enterprising finance the Netherlands Unitranche Fund SCSp

      No consideration shall be made for ‘principal adverse impact on sustainability factors’, nor does the Partnership intend to include this assessment at a later stage during the lifetime of the fund.

      The fund strategy targets Dutch lower middle market businesses where: i) available sustainability related information is limited and inconsistent in scope and subjective in its nature; and ii) the cost of doing proper due diligence relative to the size business and loans is disproportionate.

    • Exeter Funds

      Exeter Funds

      The below statements are applicable to EQT Exeter China Logistics Fund SCSp, Exeter Europe Logistics Value Fund IV S.C.SP , Exeter Europe Logistics Value Fund IV Feeder S.C.Sp , Exeter Europe Industrial Core Fund S.C.Sp. , Exeter Europe Industrial Core Fund Feeder S.C.Sp. Exeter is committed to addressing sustainability across its real estate assets through a responsible approach to economic, environmental and social aspects through all phases of the property investment cycle. Generally this means:

      > Strategically focusing efforts on identifying material risks

      > Assessing trends to anticipate opportunities for value creation and manage existing risk appropriately

      > Establishing internal processes to assess, identify, address and progress on these opportunities and risks. This is primarily done through our in-depth due diligence process upon acquisitions and these are factored into our risk analysis for our investments.

    • European Real Estate Senior Debt

      European Real Estate Senior Debt

      We currently do not formally, or to the extent set out in SFDR, take into account the principal adverse impacts of investment decisions on sustainability factors on the basis that, in the context of the investment strategies of our funds, it is not possible to conduct detailed diligence on the principal adverse impacts.

      European Real Estate Senior Debt - ESG Policy

    • FUNIS Infrastructure Investments S.C.S., SICAV-RAIF

      FUNIS Infrastructure Investments S.C.S., SICAV-RAIF

      FUNIS Infrastructure Investments S.C.S., SICAV-RAIF does not consider the adverse impacts of investment decisions on Sustainability Factors due to absence of sufficient data and lack of relevant disclosures from small target investments for the performance of an adequate assessment of the potential adverse impact of the investment decision on Sustainability Factors.

    • GALLICA III S.A.R.L. SICAV-RAIF

      GALLICA III S.A.R.L. SICAV-RAIF

      Sanne LIS S.A. as alternative investment fund manager of GALLICA III SARL SICAV-RAIF (the “Fund”) together with the Investment Adviser of the Fund, BRG ASSET MANAGEMENT LLC, does not consider the principle 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. 

    • Go Real Estate S.A., SICAV-RAIF

      Go Real Estate S.A., SICAV-RAIF

      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.

    • GTIS funds

      GTIS funds

      The below statements are applicable for:

      • GTIS Denver-Boulder Co-Invest SCS
      • GTIS US Property Income Partners 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.

      • HARRISON STREET CORE PROPERTY FUND B S.C.S., SICAV-RAIF

        HARRISON STREET CORE PROPERTY FUND B S.C.S., SICAV-RAIF

        For the Article 4 statement applicable to Harrison Street property Fund B S.C.S., SICAV-RAIF, please refer to the below document.

        HARRISON STREET CORE PROPERTY FUND B S.C.S., SICAV-RAIF

         

      • 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.

        H.I.G.

        Applicable for: 

        • H.I.G. BAYSIDE LOAN OPPORTUNITY FEEDER FUND VII (EUROPE-EURO), SCSP 
        • H.I.G. BAYSIDE LOAN OPPORTUNITY FUND VII (EUROPE-EURO), SCSP 
        • H.I.G. EUROPE REALTY PARTNERS III, SCSP 
        • H.I.G. INFRASTRUCTURE PARTNERS C, L.P. 
        • H.I.G. WHITEHORSE LUXEMBOURG LOAN FEEDER FUND - 2020, SCSP 
        • H.I.G. WHITEHORSE EUROPE LEVERED DIRECT LENDING FUND II, SCSP 
        • H.I.G. WHITEHORSE EUROPE UNLEVERED DIRECT LENDING FUND II, 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. 

      • Hillwood Development Company

        Hillwood Development Company

        In light of the uncertainty regarding the practical implementations of the SFD Regulation (“SFDR”), Hillwood has not implemented a systematic review of the principal adverse impacts of its investment decisions on Sustainability Factors as defined by the SFDR.

         

        While not explicitly contemplated at this time, Hillwood may consider the principal adverse impacts of its investment decisions on Sustainability Factors as defined by the SFDR at a later date when the applicable framework (legal, regulatory, and otherwise) is further developed and the availability of source data is such that it provides for meaningful analysis. In the meantime, Hillwood will continue to monitor and review the situation as it progresses.

      • HV Funds

        HV Funds

        Neither HV Fund - Fund of Funds, nor HV Fund – Venture Direct 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.

      • Jefferies Finance Europe

        Jefferies Finance Europe

        Jefferies Finance 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”).

        Jefferies Finance has chosen not to do so for the present time as it considers its existing ESG principles and diligence procedures to be appropriate, proportional and tailored to the investment strategy of Jefferies Finance funds. Jefferies Finance 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.

      • KÖZU funds

        KÖZU funds

        The below statements are applicable for:

        • KÖZU Private Markets 13 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.

        • 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

        • MESO Fonds S.A. RAIF

          MESO Fonds S.A. RAIF

          Meso Fonds S.A. RAIF 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. 

        • 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

        • Noal SCSp

          Noal SCSp

          Sanne LIS S.A. as alternative investment fund manager of NOAL SCSp (the “Fund”) together with the Investment Adviser of the Fund, BRG ASSET MANAGEMENT LLC, does not consider the principle 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. 

        • 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.

          Oakley Capital ESG Policy

        • 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

          In 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.

        • RECAP Opportunity Fund III SCS SICAV-RAIF

          RECAP Opportunity Fund III SCS SICAV-RAIF

          RECAP Opportunity Fund III SCS SICAV-RAIF is not 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.

        • 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

          While Slate Asset Management (Europe) Limited (“Slate”) takes into account sustainability risks in its investment recommendations related to investments made by Slate European Real Estate Fund III’s (the “Fund”), Slate does not currently consider adverse impacts of investment decisions on sustainability factors as defined by the SFDR. Slate has chosen not to do so presently as it considers its existing ESG policies and procedures to be appropriate, proportional and tailored to the investment strategies of the Fund. 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

          The AIFM together with the Investment Advisor, with respect to Smart Markets Luxembourg Fund SCSp, does not consider adverse impacts of its investment decisions on sustainability factors yet due to the absence of (i) sufficient data/ information and (ii) sufficient quality of such data/information to provide a meaningful assessment on the performance of any potential adverse impact of the investment decisions on sustainability factors.

          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 funds

          Tempus funds

          The below statements are applicable for:

          • Tempus Europe Investment Fund Sarl SICAV-SIF
          • Tempus Europe Fund III Sarl SICAV RAIF

          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

          • TRIBUS HOLDINGS, SCSP

            TRIBUS HOLDINGS, 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.

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

            www.ubs.com/global/en/asset-management/regulatory.html.

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

            www.ubs.com/global/en/asset-management/regulatory.html

          • 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

          • AltaCAM Global Credit II SC SICAV-RAIF

            AltaCAM Global Credit II SC SICAV-RAIF

            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

          • CAM Alternatives

            CAM Alternatives

            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

          • CT Europe Residential FCP-RAIF

            CT Europe Residential FCP-RAIF

            All investment decisions in relation to the Fund broadly consider the principal adverse impacts of those decisions on sustainability. 

            Please refer to the below documentation for further details on the methodologies and approaches: 

            CT Europe Residential FCP-RAIF - Article 8 Disclosure

            CT Europe Residential FCP-RAIF - ESG Policy

          • Equitix European Infrastructure II SCSp

            Equitix European Infrastructure II SCSp

            For the relevant website disclosures related to Equitix European Infrastructure II SCSp under the Sustainable Finance Disclosure Regulation please refer to the attached file: Equitix European Infrastructure II SCSp - disclosure document.

          • Digital Infrastructure Vehicle II SCSp SICAV-RAIF

            Digital Infrastructure Vehicle II SCSp SICAV-RAIF

            We believe in the societal and business benefits of a responsible Environmental, Social and Governance (ESG) policy. Through our investment advisory processes, we seek to identify, grow, and improve the Funds’ portfolio companies, ensuring long-term sustainable value creation.  

              We recognize that ESG principles can contribute to creating value for investors and all other stakeholders – both in terms of mitigating risks and seizing opportunities. However, for the time being the fund does not consider the adverse impacts of investment decisions on ESG 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. Thus, we will re-evaluate the conditions end of 2022. As soon as we start considering adverse sustainability impacts into our investment decisions, we will disclose the relevant information to investors and on our website. 

            For the relevant website disclosures related to Digital Infrastructure Vehicle II SCSp SICAV-RAIF under the Sustainable Finance Disclosure Regulation please refer to the attached file: 

            Sustainability Framework.

            Article 10 disclosures.

          • DTCP Growth Equity III SCSp, SICAV-RAIF

            DTCP Growth Equity III SCSp, SICAV-RAIF

            We believe in the societal and business benefits of a responsible Environmental, Social and Governance (ESG) policy. Through our investment advisory processes, we seek to identify, grow, and improve the Funds’ portfolio companies, ensuring long-term sustainable value creation.  

            We recognize that ESG principles can contribute to creating value for investors and all other stakeholders – both in terms of mitigating risks and seizing opportunities. However, for the time being the fund does not consider the adverse impacts of investment decisions on ESG 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. Thus, we will re-evaluate the conditions end of 2022. As soon as we start considering adverse sustainability impacts into our investment decisions, we will disclose the relevant information to investors and on our website. 

            For the relevant website disclosures related to DTCP Growth Equity III SCSp, SICAV-RAIF under the Sustainable Finance Disclosure Regulation please refer to the attached file: 

            Sustainability Framework.

            Article 10 disclosures.

          • HyCap Fund 1 SCSp

            HyCap Fund 1 SCSp

            The Manager together with the portfolio manager of the Fund, Vedra Partners Limited (the “Portfolio Manager”), have considered, and continues to consider, ESG factors in its investment process to seek to deliver risk-adjusted returns, but do not consider principal adverse impacts of investment decisions on sustainability factors as specifically set out in Regulation 2019/2088 on sustainability-related disclosures in the financial services sector dated 27 November 2019 (SFDR). The Manager and the Portfolio Manager have chosen not to do so for the present time given (i) that the legal instruments governing the consideration of principal adverse impacts are still in draft form and (ii) the challenges in obtaining the ESG data articulated by the current draft texts.

            The Manager together with the Portfolio Manager continue 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. 

            HyCap Fund 1 SCSp

          • HSBC Alternative Investments S.C.A. SICAV-RAIF Sub-Fund II (Infrastructure Basket VI)

            HSBC Alternative Investments S.C.A. SICAV-RAIF Sub-Fund II (Infrastructure Basket VI)

            The fund does not consider the adverse impacts of investment decisions on ESG 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. 

            Article 8 disclosure 

          • SC CORE LUX FUND SCSP

          • VB Private Equity SCS-RAIF

            VB Private Equity SCS-RAIF

            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

          • ZCH AM SICAV - Latam Fund

            ZCH AM SICAV - Latam Fund

            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


          Article 9 Funds disclosures