Since inception, responsible investment has been an integral part of our culture and a guiding principle. Our long history of engagement on Environmental, Social, and Governance (“ESG”) principles reflects our core belief that such matters are fundamental in achieving long term success and ultimate value creation for our investors.
Responsibility
We strive
- to ensure that due diligence, investment decisions and monitoring for each investment includes consideration of environmental, social (including health and safety, employees, human rights, consumer and community issues) and governance issues as well as the consideration of any ESG event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment (“sustainability risks”) ;
- to encourage our portfolio investments to consider ESG criteria and sustainability risks in their activities.
Our aim is to stay at the forefront of the fund-of-funds industry by actively participating in the global push towards adoption of higher ESG standards.
We endeavor to continue building on our ESG commitment. However, adopting a responsible approach shall not negatively impact on the Fund’s market strategy and investment objectives and the Management Company is required to act in the best interests of all Investors in the Fund and Investors in the parallel funds and in accordance with the Fund’s purpose and investment policies.
EU Sustainable Finance Disclosure Regulation
After careful review of the requirements set out in the EU Sustainable Finance Disclosure Regulation (“SFDR”) and draft Regulatory Technical Standards, we have concluded that our secondary investment strategy is not currently adapted to the consideration of principal adverse impacts of investment decisions on sustainability factors (the “PAI regime”) and the technical reporting requirements of such specific regime. We have therefore decided not to adopt the PAI regime for our current funds. We are however supportive of the policy aims of the PAI regime to improve transparency on how market participants integrate consideration of the adverse impacts of their investment decisions on sustainability factors. Further, the management company has decided not to include sustainability criteria in its remuneration policy (SFDR Article 5). We will continue to engage with our partners on these matters and keep this decision under regular review.
Policy in terms of voting rights
In accordance with Article L533-22-I of the French Monetary and Financial Code and Decree n° 2019-1235 dated 27 November 2019, Committed Advisors is required to either develop and publicly disclose a « shareholders engagement policy » describing how shareholder engagement is integrated in its investment strategy, and to publicly disclose on an annual basis the implementation of such policy, or to publicly disclose a clear and reasoned explanation as to why it has chosen not to do so. It is not currently appropriate for Committed Advisors to develop a shareholder engagement policy, based on its funds’ investment strategy as funds-of-funds which generally only hold shares of companies through intermediate entities managed by a third-party and therefore do not exercise any voting rights in such companies.
