Integration of sustainability risks in our remuneration policies:
As per Article 5 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 (the “SFDR”), Financial Market Participants shall include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks and shall publish that information on their websites.
Consulco Capital Ltd’s (“the Company”) remuneration policy is consistent with the integration of sustainability risks and incorporates measures to ensure that, it does not encourage excessive risk taking, including risk taking in terms of sustainability risk (including greenwashing risks).
The Company’s Remuneration Policy promotes, amongst others, the following practices which are consistent with the Company’s sustainability risk policies:
– promoting sound and effective risk management and a fee structure which does not encourage risk-taking which is inconsistent with the risk profiles and objectives of the underlying funds/ fund compartments under management,
– fixed and variable components of total remuneration are appropriately balanced, and the fixed component represents a sufficiently high proportion of the total remuneration to allow the operation of a fully flexible policy, on variable remuneration components, including the possibility to pay no variable remuneration component,
– ensuring that the assessment of performance includes a comprehensive adjustment mechanism to integrate all relevant types of current and future risks,
– taking into consideration both financial as well as non-financial criteria when assessing individual performance.
Integration of sustainability risks in the investment decision-making process:
Sustainability risk means an environmental, social or governance (ESG) event or condition that, if it occurs, could cause actual or potential material negative impact on the value of the investment.
The Company does not offer alternative investment funds that seek to promote one or more environmental or social characteristics, nor does it have sustainable investment as its objective. The funds under management are therefore considered as “Article 6” financial products in accordance with SFDR.
In compliance with the obligations under the SFDR, the Company integrates Sustainability Risks into the investment decisions, meaning, a process is followed by which first such risks (if any) are identified and, where relevant, monitors and manages such risks which may impact the Funds in a manner considered to be appropriate to the particular investment strategy of a Fund and consistent with the best interests of the Investor Shareholders.
Sustainability Risks are part of the investment risk management framework taken into consideration along with other risk factors as part of the wider investment decision making process. The main sustainability risks that indirectly relate to the Funds under management at the moment are environmental risks which can be divided into physical risks and transition risks. Following risk mitigation and due diligence measures taken, the Company considers that current sustainability risks on the investment portfolios are of a lower risk and the impact of such risks on investment returns is not considered as material. If, however, in the future sustainability risks identified may have a material and negative impact on the returns of the Funds, relevant risk mitigation strategies will be put in place.
Further information can be found in the Company’s Sustainability Risk Policy.
No consideration of adverse impacts of investment decisions on sustainability factors:
Principle adverse impacts (“PAIs”) are potential adverse effects of investment decisions on sustainability factors. Sustainability factors are environmental, social and employee matters, respect for human rights, anti-corruption, and anti-bribery matters.
In accordance with Article 4(1)(a) 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 (the “SFDR”), financial market participants shall publish and maintain on their website where they consider PAIs of investment decisions on sustainability factors a statement on due diligence policies with respect to those impacts taking due account of their size, the nature and scale of their activities and the types of the financial products they make available.
Where financial market participants 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 must be disclosed.
As per Article 12 of Commission Delegated Regulation (EU) 2022/1288, Consulco Capital Ltd (“the Company”) in its capacity as a Financial Market Participant, for the time being, except as may be otherwise disclosed at a later stage on our website, does not consider principal adverse impacts of investment decisions on sustainability factors due to the fact that currently such considerations are deemed not to be material to the Funds’ investment strategy. In the event that sustainability factors do, in the future, become material, the Company will consider the principal adverse impacts of its investment decisions on sustainability factors.