Sustainability-Related Disclosures

Published on March 9, 2023

RSM Fund Management Luxembourg takes potential sustainability risks and/or opportunities into consideration in its analysis of investment opportunities and the investment decision-making process in accordance with the provisions set out in Regulation (EU) N°2019/2088 of the European Parliament and of the Council of 27 November 2019 (as amended) on sustainability-related disclosures in the financial sector (SFDR).

Portfolios are managed by integrating environmental, social and governance (ESG) risks and factors on a case-by-case case basis and depending on the characteristics of each proposed individual portfolio investment, including for products which do not promote ESG characteristics or have specific sustainable investment objectives. This means that whilst ESG factors are considered, they may or may not impact portfolio construction. The impact of ESG integration on investment performance may change over time.

The individual sustainability/ESG risk factors considered for each specific investment depend on each of the managed AIF’s investment strategy as well the economic sector and geographical exposure of the targeted investment, and may notably include:

  • Environmental: Material negative impacts from investment decisions relating to the quality and functioning of the natural environment and natural systems, including greenhouse gas emissions, use of non-renewable energy, biodiversity, water and waste;
  • Social: Material negative adverse impacts from investment decisions relating to the rights, well-being and interests of people and communities; and
  • Governance: Material negative adverse impacts from issues relating to the governance of companies, including inappropriate management of conflicts of interest, violation of anti-money laundering rules, etc.

No consideration of adverse impacts of investment decisions on sustainability factors

RSM Fund Management Luxembourg does at present not consider and disclose adverse sustainability impacts in accordance with point (a) of Article 4(1) of SFDR on a “Financial Market Participant” basis. This is due to the absence of (i) sufficient data/information, and (ii) sufficient quality of such data/information for the assessment of potential adverse sustainability impacts at the time of investment and on an ongoing basis. Moreover, RSM Fund Management manages products with a wide variety of investment strategies and underlying assets, both in type of assets and size of investments. The meaningfulness of the data and an assessment of its evolution appear therefore significantly impaired.

However, principal adverse impact policies and statements for certain products or subsets of products may be published hereunder in the future where relevant.

Disclosure regarding the Integration of Sustainability Risks in RSM Fund Management Luxembourg Remuneration Policies

The Remuneration Policy of RSM Fund Management Luxembourg integrates sustainability-related aspects; in particular:

  • The criteria for periodically determining individual and collective variable remuneration incentives shall take due account of present and future sustainability-related risk factors;
  • The delegated portfolio manager’s remuneration policies shall include appropriate and equivalent provisions in relation to the integration of sustainability risks.