Transparency of sustainability risk policies

The following disclosure is made by Saphire Management S.à r.l. (the “AIFM”) pursuant to Article 3 of 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, as amended ("SFDR").

In accordance with this article, financial market participants, such as the AIFM, shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process.

“Sustainability risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Sustainability risks are considered as part of the overall investment and risk assessment process of the AIFM, where relevant and proportionate to the investment strategy of the alternative investment funds (“AIFs”) under management.

Sustainability risks may be environmental, social or governance-related and may vary depending on the nature, geography and lifecycle stage of each investment.

Sustainability risks are assessed qualitatively and integrated alongside other relevant risk factors, such as market risks, liquidity risks and counterparty risks in the AIFM’s investment decision-making process. Sustainability risks are integrated into the AIFM’s investment due diligence policies.

Environmental, social, and governance (ESG) data is indeed integrated into the investment decision-making process of the AIFM, together with traditional financial information, in order to ensure that investments of each AIF are managed consistently with its sustainability strategy.

Transparency of adverse sustainability impacts

The following disclosure is made by the AIFM pursuant to Article 4 SFDR.

In accordance with this article, financial market participants, such as the AIFM, shall publish and maintain on their websites, where they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons for why they do not do so, including, where relevant, information as to whether and when they intend to consider such adverse impacts.

“Sustainability factors” mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

At this stage, the AIFM does not consider the principal adverse impacts of investment decisions on sustainability factors, as referred to in Article 4 of SFDR.

This approach reflects the current scale of operations and the limited availability of relevant and reliable data across the various investment strategies of the AIFs under management. The AIFM keeps this position under review and may reassess it as its business and investment activities evolve.

Certain investments may incidentally contribute to innovation, skills development or economic activity in emerging markets in which there is a lack of accurate and reliable ESG data..

Disclaimer

Saphire Management S.à r.l. is not yet registered as alternative investment fund manager in accordance with Article 3(3) of the Luxembourg law of 12 July 2013 on alternative investment fund managers. However, a request for registration as alternative investment fund manager has been submitted to the Commission de Surveillance du Secteur Financier ("CSSF"), the supervisory authority of the financial sector of the Grand Duchy of Luxembourg.

Saphire Management S.à r.l. is currently awaiting confirmation of registration from the CSSF. 

In the meantime, Saphire Management S.à r.l. remains fully aware of and committed to complying with its legal and regulatory obligations.