No Consideration of Sustainable Adverse Impacts



Sustainable Finance Disclosure Regulation (“SFDR”)

The following statement only applies to members of the Albourne Group (consisting of Albourne Partners Limited and its subsidiaries, “Albourne”) that provide services to clients in the EU and are subject to the SFDR (each a “SFDR Subsidiary” and, collectively, the “SFDR Subsidiaries”).

Integration of sustainability risks:

A “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 return of an investment.

Albourne is a non-discretionary adviser, which produces research on fund managers. That research examines, among other things, the ability of fund managers to execute their chosen investment strategy but does not constitute investment advice or recommendations regarding the underlying investments made by fund managers on behalf of the funds or accounts they manage.

Since 2 August 2022, investment advisory clients in the EU must be asked about their sustainability preferences, which includes asking clients whether and to what extent they wish to invest in a financial product (including the specification of a minimum proportion):

  1. that contains a minimum proportion of environmentally sustainable investments as defined by the Taxonomy Regulation,
  2. that contains a minimum proportion of sustainable investments as defined by the SFDR, or
  3. that considers the principal adverse impacts on sustainability factors.

Following Albourne’s enquiry regarding sustainability preferences:

  1. if an investment advisory client in the EU has expressed sustainability preferences, the relevant SFDR Subsidiary’s investment recommendations to that client will take into account the client’s expressed sustainability preferences; or
  2. if no sustainability preferences have been expressed, the relevant SFDR Subsidiary will not consider such preferences when making investment recommendations.

The SFDR Subsidiaries’ investment recommendations that take into account a client’s expressed sustainability preferences are informed by information regarding material sustainability risks obtained from fund managers through Albourne’s investment due diligence, operational due diligence and sustainability integration questionnaires.

Integration of sustainability risks in remuneration policies:

As a non-discretionary advisor that does not have proprietary positions, Albourne does not remunerate staff by reference to the risks they assume for Albourne or their clients. Therefore, Albourne does not deem sustainability risks to be relevant in this context.

No Consideration of Principal Adverse Impacts (“PAIs”) on Sustainability Factors:

The SFDR Subsidiaries only provide research and recommendations in relation to a fund manager’s ability to integrate sustainable factors into a fund’s investment process. The SFDR Subsidiaries are not in a position to consider the adverse impacts of a fund manager’s investment decisions on sustainability factors or sustainability risks in their investment advice because those investment decisions are taken by the fund managers. In addition, each fund manager may take a different approach to the consideration of sustainability factors, and whilst some fund managers may elect to consider principal adverse impacts on sustainability factors, others may not. As such, adverse impacts of investment decisions are defined at the level of each investment strategy and can vary from one strategy to the other. Where an investment strategy considers PAIs, the approach for considering those impacts can be found in the pre-contractual documentation of the concerned strategy in accordance with article 7(1) of the SFDR.