Disclosures for the Sustainable Finance Disclosure Regulation (“SFDR”) [1] 

 

These disclosures are made for the purposes of Articles 3(1), 4and 5 Regulation (EU) 2019/2088, known as the Sustainable Finance Disclosure Regulation or SFDR. It is made by Gestron Asset Management S.A. (“Gestron”), a société anonyme established in Luxembourg, which has legal entity identifier (LEI) code 254900FT6VM7L1OKQN52. Gestron is an alternative investment fund manager authorized by the Commission de Surveillance du Secteur Financier (hereinafter “CSSF”) in Luxembourg under Chapter 2 of Luxembourg Law of 12 July 2013 on alternative investment fund managers.

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1.    Information on the integration of sustainability risks in investment decision‐making process (article 3 SFDR)

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• Gestron identifies and analyses environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of an investment (“Sustainability Risks”) as part of its risk management process. Gestron believes that the integration of this risk analysis could help to enhance long-term risk adjusted returns for investors, in accordance with the investment objectives and policies of the alternative investment funds under Gestron’s management. Where Sustainability Risks occur for assets of a specific alternative investment fund, there will be a negative impact on such alternative investment fund that may result in a negative impact on the returns for the investors of such alternative investment fund. 

• Sustainability Risks may not be considered by Gestron to be relevant because Sustainability Risks are not (a) systematically integrated by Gestron in the investment decisions of the relevant alternative investment fund; and/or (b) a core part of the investment strategy of the alternative investment funds, due to the nature of the investment objectives of the alternative investment funds. However it cannot be excluded that among other counterparties or sectors in which such alternative investment funds will invest may have bigger exposure to such Sustainability Risks than others. Sustainability Risks do not form a separate risk category, but the effects of Sustainability Risks are manifesting themselves in the different risk categories (e.g. market risk). An ESG event or condition that, if it occurs, could potentially or actually cause a material negative impact on the value of an alternative investment fund’s investment. Sustainability risks can either represent a risk of their own or have an impact on other risks and may contribute significantly to risks, such as market risks, operational risks, liquidity risks or counterparty risks.  Consequent impacts to the occurrence of Sustainability Risks can be many and varied according to a specific risk, region or asset class.

 

2.    Information on the integration of Sustainability Risks in the remuneration policy (article 5 SFDR)

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• Gestron's remuneration policy supports appropriate management of all relevant business risks by including Sustainability Risks in accordance with the SFDR. Gestron has defined key risk indicators to assess Sustainability Risks related to variable compensation. These risk indicators can be quantitative or qualitative and reflect the relevant environmental, social and governance aspects as well as the main principal adverse impacts and are defined in such a way that the remuneration structure does not encourage excessive risk-taking in relation to direct or indirect Sustainability Risks. The remuneration policy is designed in order to be consistent with and to promote sound and effective risk management including Sustainability Risks and does not encourage risk-taking, which is inconsistent with the risk profile of the alternative investment funds under Gestron’s management.

• All Gestron staff receive a combination of fixed and variable remuneration with the ratio of fixed to variable remuneration, among other factors, ensuring that the remuneration structure applicable to the Gestron staff has a limited impact on the risk profile of the alternative investment funds under Gestron’s management.

• In light of the limited impact of the Gestron’s remuneration structure in respect of its staff on the risk profile of the alternative investment funds, in addition to the nature of the business of Gestron, Gestron believes there is no risk of misalignment with the Sustainability Risks associated with the investment decision making process of Gestron in respect of the alternative investment funds. 

 

3.    Principal adverse impact statement – No consideration at entity level

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• Gestron has chosen for the time being not to consider principal adverse impacts of investment decisions on sustainability factors. The main reason for which the Company is currently not considering adverse impacts is the absence of sufficient data and data of a sufficient quality to allow the Company to define material metrics for disclosure. Gestron will continue to assess its position as the market practice develops in this area. This decision will be reassessed on a regular basis.

 

This page was last updated on 6 March 2023. [2] 

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[1] SFDR means Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector”. 

[2] The Company reserves the right to update this disclosure from time to time at its discretion.