The EU Sustainable Finance Disclosure Regulation (SFDR) (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector, or the Disclosure Regulation for short, obliges financial market participants to publish information on how they incorporate sustainability risks in their decision-making process regarding investments, how they take into account the most important adverse sustainability impacts of investment decisions, how they ensure transparency in relation to the marketing of ecological or social factors and how they envisage achieving sustainable investment goals.
We strive to be as transparent as possible with regard to the role that ecological, social and governance factors (ESG) play in our investment process. It is our aim to promote sustainable investments, to minimise sustainability risks and to exploit sustainability opportunities in order to contribute to shaping a better future. We believe that our duty as asset managers to act in the interests of our customers for the long term includes the principles of sustainable investment and that a healthy ESG impact has a favourable effect on the risk/profit profile of our investments.
The Disclosure Regulation obliges financial market participants to provide information on their websites on how they incorporate sustainability risks into their investment decision-making process. According to the Disclosure Regulation, sustainability risks are events or conditions the occurrence of which could cause an actual or potential material negative impact on the value of the investment.
We are aware that sustainability risks can have an enormous impact on the financial performance of our assets. Sustainability risks, including climate risks, are therefore taken into account in our global risk assessment. In the process, we assess how large the specific risks are and what their potential impact is, in particular on our returns.
We calculate sustainability risks at company and at portfolio level. The specific risks that we take into account with an investment depend on the asset class and the type of financial product as well as other factors, such as investment spectrum, structure, sector, scope and geographical position. The procedure for assessing the possible impact of sustainability risks on the returns of an investment therefore differs from case to case. Additional information on the different types of sustainability risks that can have an influence on an investment’s return may be found in the corresponding investment brochure.
The Disclosure Regulation requires financial market participants to report on their websites how they assess the principal adverse impacts of investment decisions on sustainability factors at company level. According to the Disclosure Regulation, the most important adverse impacts of investment decisions and investment advice are those which have a negative impact on sustainability factors.
At Patrimonium, the most important adverse impacts of investment decisions on sustainability factors are not considered systematically. This is primarily because insufficient sustainability data is available for private market investments. Although we do everything in our power to collect this type of data for our potential investments, acquiring the necessary ESG information can be difficult.
We regularly review our duties and our procedures in connection with the most important adverse impacts of our investment decisions on sustainability factors.
According to the Disclosure Regulation, financial market participants must include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks.
Our ability to evaluate and minimise sustainability risks and to integrate ESG factors has a positive effect on the performance and the success of our company and the individual business units and thus influences the (amount of the) performance-based remuneration.
Sustainability and ESG goals, such as the implementation of ESG principles and the achievement of specific ratings, are also company goals that are considered when assessing the total performance-based remuneration.