Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial service sector (“SFDR”).
The investments underlying the Fund do not take into account the EU criteria for environmentally sustainable economic activities.
Article 6 of the SFDR requires that the AIFM (Carne Global Fund Managers) and the Investment Manager (Farringdon Netherlands BV) disclose the manner in which sustainability risks are integrated into investment decisions with respect to the Fund and the results of the assessment of the likely impacts of sustainability risks on the returns of the Fund, and where the AIFM and the Investment Manager deem sustainability risks not to be relevant, the description shall include a clear and concise explanation for this.
A sustainability risk in this context 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.
The AIFM and the Investment Manager have deemed it not relevant that sustainability risks are integrated into investment decisions for the Fund, as the consideration of sustainability risks is not mandated by the investment policies of the Fund.
The Fund ordinarily seeks to invest directly in equities, collective investment vehicles or certain market segments in which the Investment Manager determines to invest, in order to meet the investment objectives. While the Fund will primarily invest directly in equities, indirect exposure to equity benchmarks or indices may be sought by way of investment in collective investment schemes where in the best interests of the Fund to do so. Certain of the collective investment schemes in which the Fund invests may take ESG factors and sustainability risks into account when implementing their investment policy, however this is not a material factor in the investment making decision process of the Investment Manager in selecting collective investment schemes in which the Fund invests.
As such, the consideration of sustainability risks does not play a role in the investment decision-making process in respect of the Fund, and the impact of sustainability risks is not relevant to the returns of the Fund.
ADVERSE SUSTAINABILITY IMPACTS
The AIFM in conjunction with the Investment Manager does not consider principle adverse impacts on the basis that, in the context of the investment strategies of the Fund, it is not possible to conduct detailed diligence on the principal adverse impacts of the Investment Manager's investment decisions on sustainability factors.