Sustainable Finance Disclosure Regulation (“SFDR”)
Under the Sustainable Finance Disclosure Regulation (EU) 2019/2088 (“SFDR”), “Sustainability Factors” mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. “Sustainability Risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.
Investment Manager’s investment process takes into account an assessment of Sustainability Risks throughout the life cycle of an investment, from the preliminary screening to final investment proposal, and subsequently during periodic investment reviews. Due to the size of Investment Manager’s operations and significant resources required to implement a formal monitoring programme, Investment Manager does not currently assess adverse impacts that its investment decisions may have on Sustainability Factors.
By taking Sustainability Risks into consideration during its investment decision making process, the Investment Manager seeks to manage Sustainability Risks in a way that they do not have a material adverse impact on the performance of the Master Fund. However, no assurance can be given that the Investment Manager will be able to avoid and/or mitigate the impact of Sustainability Risks on the Master Fund and losses may be incurred.
The investments held in the Master Fund are exposed to different geographies and sectors of the economy and are therefore exposed to various Sustainability Risks, including but not limited to:
Environmental
Air and water pollution, hazardous waste spills, environmental disasters (eg wildfires, floods, hurricanes, locusts).
Social
Discrimination, conflict, unsafe working practices, unethical procurement practices, organised crime, human rights abuses.
Governance
Bribery and corruption, money laundering, fraud, sanctions, expropriation, cyber-attacks.
