The European Commission’s Sustainable Action Plan has three objectives: (1) To reorient capital flows towards sustainable investment in order to achieve sustainable and inclusive growth; (2) To manage financial risks stemming from climate change, environmental degradation, and social issues; and (3) To foster transparency and long-termism in financial and economic activity. It is a response to recommendations from the high-level expert group on sustainable finance, which were submitted to the Commission in January 2018.
Already, the European Parliament has adopted an amendment to Regulation 2016/1011 to introduce a framework for EU climate transition and EU Paris-aligned benchmarks, an amendment to the Delegated Regulation 2017/565 to integrate environmental, social, and governance (ESG) considerations into investment advice and portfolio management, and an amendment to Delegated Regulation (EU) 2017/2359 to integrate ESG considerations and preferences into the investment advice for insurance-based investment products. It has also prepared a series of related reports, including an EU Taxonomy Regulation, benchmarks, EU green bond standard, and climate-related disclosures.
SFDR which is part of a broader legislative package under the European Commission’s Sustainable Action Plan, came into effect on 10 March 2021. To meet the SFDR disclosure requirements, the AIFM identifies, assesses and, where possible and appropriate, seeks to manage sustainability risks for the Partnership as part of its risk management process. The AIFM believes that the integration of this risk analysis could help to enhance the long-term value of the portfolio for Investors, in accordance with the investment objective and Investment Policy of the Partnership.
The Partnership is promoting environmental or social characteristics within the meaning of article 8 of SFDR and has sustainable investment as its objective within the meaning of article 9 of SFDR. For the purposes of Article 9 of the EU Taxonomy Regulation, the AIFM confirms that the investments underlying this financial product (i.e. the Partnership) does take into account the EU criteria for environmentally sustainable economic activities.
As regards disclosures obligations under article 4(1) of SFDR it is confirmed that the AIFM does take into account the negative impacts due to investments – Article 4 (1) (a).
These SFDR Disclosures are prepared on the basis of the ANNEX III published by the European Commission on June 4th 2022 – Template pre-contractual disclosure for the financial products referred to in Article 9, paragraphs 1 to 4a, of Regulation (EU) 2019/2088 and Article 5, first paragraph, of Regulation (EU) 2020/852.
