SFDR
SFDR which is part of a broader legislative package under the
European Commission`s Sustainable Action Plan, came into effect on 10 March
2021.
To meet the SFDR disclosure requirements, the Luxembourg AIFM identifies,
assesses and, where possible and appropriate, seeks to manage Sustainability
Risks for the Partnership as part of its risk management process. The Luxembourg
AIFM believes that the integration of this risk analysis could help to enhance
the long term value of the portfolio for Investors, in accordance with the
Investment Objective and Investment Policy of the Partnership. However, due to
the nature of the Investment Objective, Sustainability Risks are not integrated
in the investment decisions.
For the avoidance of doubt, the Partnership is not promoting environmental or
social characteristics within the meaning of article 8 of SFDR nor has
sustainable investment as its objective within the meaning of article 9 of SFDR.
For the purposes of Article 6 of the EU Taxonomy Regulation, the Luxembourg AIFM
confirms that the investments underlying this financial product (i.e. the
Partnership) do not take into account the EU criteria for environmentally
sustainable economic activities. The Luxembourg AIFM does not, and does not
intend to, consider adverse impacts of investment decisions on sustainability
factors, as per Article 4 1.b) of SFDR.