This statement relates to the requirements as set out in the SFDR regarding the consideration of principal adverse impacts of investment decisions on sustainability factors. Under the SFDR, principal adverse impacts are understood to mean: those effects of investment decisions and advice that result in negative consequences for sustainability factors.
The Fund Manager does not take into account the adverse impacts of investment decisions on sustainability factors and therefore does not prepare an annual so-called “principal adverse sustainability impact statement” (PAI statement). The Fund does not promote environmental or social characteristics and does not have sustainable investments as its objective. Therefore, the Fund does not actively seek to mitigate adverse impacts on sustainability factors.
In addition, taking into account the adverse impacts of investment decisions on sustainability factors would require the Fund Manager to obtain the necessary information to be able to report on these factors. The Fund Manager believes that there is currently insufficient reliable data available to determine the potential negative effects of its investments with regard to sustainability.
The Fund Manager is of the opinion that, also taking into account the nature, scale, and the stage in which the Fund Manager finds itself (managing a single fund without promoting sustainable factors), the costs of including sustainability-related adverse impacts in the investment process do not outweigh the expected benefits. At this stage, the Fund Manager does not take into account principal adverse impacts of investment decisions on sustainability factors within the meaning of the SFDR regulation.
The above does not prevent the Fund Manager from reconsidering the decision not to take into account adverse impacts of investment decisions on sustainability factors should relevant circumstances arise. For example, if the majority of investors value the consideration of adverse impacts of investment decisions on sustainability factors (and thus a PAI statement). At the time of publication of this information, however, this is not expected.