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.

Luxembourg Investment Solutions ESG Policy

LIS 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, Luxembourg Investment Solutions 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

A10 EUR (Feeder) SCS

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 were not settled by 10 March 2021 when we were required to decide and publish our initial approach. We are continuing to assess the mandatory data collection and disclosure requirements around these.

A10 EUR (Feeder) SCSp - ESG Policy

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

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)

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 X EUR SCSp

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 were not settled by 10 March 2021 when we were required to decide and publish our initial approach.  We are continuing to assess the mandatory data collection and disclosure requirements around these.

Apax X EUR SCSp - ESG Policy

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

 

 

Best Value Europe II FCP RAIF

Best Value Europe II FCP RAIF

BentallGreenOak Luxembourg Funds SCSp, SICAV-FIAR

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

BLUEVEST S.C.A., SICAV-RAIF

Bluevest 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 Funds I and II

Pursuant to the Limited Partnership Agreements (LPA) BID Equity Funds´ I and II 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 Funds´ I and II 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 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 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

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.

CAM Alternatives

Article 4 statement applicable to all Funds for which CAM Alternatives acts as Investment advisor:

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

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.

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

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

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

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

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.

Exeter Europe Industrial & Logistics Funds

The below statements are applicable to 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.

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.

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.

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 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.

GTIS US Property Income Partners SCS

GTIS US Property Income Partners 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 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

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

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

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 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 Private Markets 13 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.

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

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 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

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

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

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 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.fileadmin/user_upload/Oakley_Capital_ESG_Policy.pdf

Oakley Capital ESG Policy

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 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

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

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

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

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

Private Capital Pool SICAV-SIF

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

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

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 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.

Silverfern Funds

The below statement applies to Silverfern SCSp RAIF , Silverfern Global Opportunities Fund III L.P. , Silverfern DBD SCSp RAIF. At the present time, the Partnership will not consider adverse impacts of investment decisions on sustainability factors as specifically contemplated by the SFDR as the information reported to it in relation to investments of the Partnership do not enable to do so. The Partnership will keep its position in this respect under review as reporting practices develop and may consider adverse impacts of investment decisions on sustainability factors as specifically contemplated by the SFDR in the future it is deemed practical and appropriate to do so.

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 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.

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

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 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 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

For the Article 4 statement in place for UBS (Lux) Real Asset Feeder and Master Funds, please refer to the link: https://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:
https://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

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 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

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

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

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

SC Core Lux Fund SCSp

Assessment of principal adverse impacts of investment decisions on sustainability factors is complex and may be based on data which within the investment objective and strategy of the Fund is difficult to obtain and incomplete, estimated or otherwise materially inaccurate. Even when identified there can be no guarantee that this data will be correctly assessed.

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

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

Blue Like an Orange Sustainable Capital Fund SICAV-SIF SCS

Blue Like an Orange Sustainable Capital Fund SICAV-SIF SCS does consider principal adverse impacts of investment decisions on sustainability factors. Relevant details are included in the Fund specific ESG Policy.

Blue Like an Orange Sustainable Capital Fund ESG Policy

Franklin Templeton Social Infrastructure Fund, SCA

Franklin Templeton Social Infrastructure Fund, SCA does consider principal adverse impacts of investment decisions on sustainability factors. For relevant details please refer to the Article 4 statement below.

Franklin Templeton Social Infrastructure Fund, SCA Article 4 statement

Franklin Templeton Social Infrastructure Fund, SCA Article 9 Disclosure


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