Below is the approach of Capitalia Fund Management AIFP, SIA to management of sustainability risks in relation to its financial products and services.
Non-consideration of sustainability risks (SFDR Article 3)
Capitalia Fund Management AIFP, SIA does not take sustainability risks into account in its investment decisions. Sustainability risks are defined as environmental, social or governance (ESG) events or conditions that, if they occur, could cause an actual or potential material adverse impact on the value of fund assets managed by Capitalia Fund Management AIFP, SIA. The decision to exclude sustainability risks from investment decision-making is mainly based on company size and data availability. Considering the current size and available resources of Capitalia Fund Management AIFP, SIA, we may lack resources to perform a proper sustainability risk assessment, and we have decided to focus on our core competencies. Issuers and companies included in our fund portfolios generally do not provide data required to systematically, consistently and at reasonable cost consider sustainability risks.
Non-consideration of adverse impacts of investment decisions on sustainability factors (SFDR Article 4)
Capitalia Fund Management AIFP, SIA does not take into account principal adverse impacts (PAI) of investment decisions on sustainability factors. Adverse impacts of investment decisions on sustainability factors include, for example, negative impacts on environment, social and employee matters, respect for human rights, and anti-corruption resulting from an investment decision. The decision to exclude PAI considerations from investment decision-making is mainly based on investment strategy, fund operating status and size. Company size and data availability also contributed to this decision. Two of our managed funds do not make new investments, and these financial products are not offered to prospective investors. Investments in these funds are illiquid and represent a small share of portfolio companies. Implementing PAI considerations would not provide practical benefit. Our active fund is relatively small and cannot materially influence PAI. As with sustainability risk assessment in investment decision-making, we may lack resources to perform a proper assessment of principal adverse impacts (PAI). Issuers and companies included in our fund portfolios generally do not provide data required to systematically, consistently and at reasonable cost consider PAI.
Remuneration policy (SFDR Article 5)
Considering the decision not to include sustainability risks and PAI considerations in investment decision-making, the remuneration policy of Capitalia Fund Management AIFP, SIA employees does not include sustainability risk management considerations.
Information at financial product level (SFDR Article 7)
Capitalia Fund Management AIFP, SIA applies the approach described in this document to the alternative investment funds it manages. As funds are not publicly marketed, fund-specific information is provided to each prospective investor by sending a pre-contractual disclosure document.
Future plans and possible policy changes
Capitalia Fund Management AIFP, SIA ensures compliance with all relevant regulations and periodically reviews policies to ensure continuous compliance. This includes making necessary disclosures in a clear, concise and accessible manner. Although Capitalia Fund Management AIFP, SIA acknowledges the importance of sustainability, its investment strategy, organisational structure and business operations regarding integration of sustainability risk and PAI currently remain unchanged. Capitalia Fund Management AIFP, SIA may change its approach to sustainability risk management if its product range, company size or applicable regulation changes in the future. In that case, we will disclose our new approach to sustainability risk management on the website.
