Disclosure Regulation

Background to increased requirements for sustainability-related information within the framework of the Sustainable Financial Disclosure Regulation

As of March 10, 2021, the EU Regulation [(EU) 2019/2088] on sustainability-related information (also known as SFDR or the Disclosure Regulation) begins to take effect. The regulation requires certain sustainability-related information to be provided with an objective to increase transparency on how financial actors, such as fund companies and individual funds, integrate sustainability risks and factors in their investment processes and how sustainability aspects may affect future returns. The same regulation applies to fund companies that manage funds for external fund managers on a contract basis with the support of a permit to offer discretionary portfolio management services. The goal is to ensure as good a comparison as possible between markets and products. The regulation is part of the “EU action plan: Financing Sustainable Growth”, which aims to contribute to sustainable development and achieve the objectives of the Paris Agreement.

On this page, we have collected all information related to the requirements set by SFDR. However, it is important to note that the details on how the requirements set by the Disclosure regulation should be met is not yet adopted, which leads to uncertainty on how the rules should be applied. The technical standards are expected to be adopted continuously throughout 2021 and come into effect by the turn of the year 2021/2022. During the transition period, fund companies must, to the best of their ability, live up to the expectations on the information in the regulation. The information on this page will therefore be adapted and updated as the EU’s final requirements, guidance, templates, and any additional standards fall into place.

The company’s view on responsible investments

The company’s goal is to create a long-term, risk-adjusted return on assets under management. The overall objective of responsible investments and corporate governance is to act in a way that promotes conditions for long-term sustainable development in the companies in which the funds have invested in order for the companies’ value, and thus the value of the funds, to develop in the long term. The company, therefore, believes that the assignment from the investors includes integrating significant sustainability-related risks and opportunities in the investment process and exercising the ownership role in a responsible manner. This view is reflected in the Company’s remuneration policy, which is available here, and in the Company’s ESG policy, which can be found here.

Principal Adverse Impact

The company conducts systematic sustainability work and takes into account for example sustainability factors and sustainability risks using a number of ESG tools when conducting the investment process. However, the company has decided not to state that it takes into account the principal adverse impact of investment decisions for sustainability factors according to article 4 in SFDR. The reason for this is the following:

In order to be able to assess the principal adverse impact of investment decisions on sustainability factors, the negative consequences that arise in the investments made in the funds and the mandates need to be able to be screened and measured in a reliable manner. In order to be able to carry out such measurements, there needs to be standardized data from the portfolio companies (eg through the work currently underway within the IOSCO Sustainable Finance Network). Given the current lack of data, the Company does not believe that it can measure the principal adverse impact of investments for sustainability factors in a reliable manner. In addition, work is underway within the EU to establish common detailed rules for SFDR. Within the framework of this work and subsequent regulations, the mandatory and voluntary indicators that are relevant and set up to measure adverse impact will be determined.

Against this background, and in order to make sure that the information given out by the company is not misleading, the Company has chosen to delay stating that it takes into account the principal adverse impact of investment decisions for sustainability factors to ensure that the information provided is not misleading. The company follows developments on the subject and intends to comply with the principal adverse impact of investment decisions for sustainability factors as soon as dependable measurements can be made and reliable information can be provided.

For more detailed information regarding the sustainability specifics for each of the Alternative Solutions funds, please contact info at carneosolutions.com.