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Responsible and Sustainable Investing by the Company

In managing the investments of the respective funds under management (the “Funds”), Altarius Asset Management Limited (“Altarius” or “the AIFM”) shall aim to take into account, to the extent applicable, sustainability risks and the potential impact of such risks on the returns of the respective Fund investments. A sustainability risk is an environmental, social or governance (“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 are referred to as “ESG risks”).

In particular, as part of the investment due diligence process certain governance risks (including management structure and compensation, and board composition) and social risks (including product safety and public health and safety) may be considered alongside other material risks in respect of the target companies and investment products. The due diligence process shall take into account publicly available information and, when and where applicable, discussions with the management of the target companies and other key stakeholders. Any ESG risks will be reflected in the investment memoranda considered by the investment committee of the AIFM as part of its investment management process. 

In light of the investment policies of the respective Funds, Altarius generally considers that the potential impact of ESG risks on the returns of Funds under management to be low. However, no assurance can be given that ESG risks will be avoided or, in the event that they arise, effectively mitigated and losses may be incurred.

Negative and Positive Screening

We will actively engage with our clients to understand whether they have concerns about specific activities and/ or industries in order to maintain such exclusions on an on-going basis. In such cases, we will undertake – to the extent possible – to screen target entities and/ or products that promote and provide solutions that are consistent with ESG Factors and shall aim to invest in such products on an on-going basis, as applicable.


The AIFM’s exposure to the sectors identified below would be reduced to a minimum, so that critical issues, as well as specific unmitigated risks, could lead to stop the acquisition process. In this respect, the AIFM may seek the prior advice of the respective investment advisors and/or investment analysts involved within the respective Fund in all cases in which it is willing to carry out an investment in a business whose exclusion from the restricted sectors below is uncertain or when the incidence of the restricted activities on the overall business of the target company is low or minimizeable. Moreover, the AIFM might depart from the aforementioned investment restrictions subject to the prior approval of the investment advisors and/or investment analysts which, in any case, cannot waive the minimum legal and diversification requirements. The aforementioned sectors may, inter alia, include target investments into:

a)    Companies whose business activity consists of illegal economic activity of any kind,

b)    Companies that substantially focus on the financing and production of a trade-in weapons and ammunition (it being understood that this restriction does not apply to the extent such activities are part of or accessory to explicit European Union policies).


Principle Adverse Impacts

When applicable, Altarius is committed to using its best efforts to take into account the potential adverse impact of its investment decisions. However, it shall be noted that non-financial data of SMEs are not always available in satisfactory quality and quantity to allow the AIFM to fully assess the potential adverse impact of the AIFM’s investment decisions on the global sustainability factors.

In considering the above, and due to the size of the AIFM’s operations and the significant resources required to implement a formal monitoring programme, Altarius does not currently assess the adverse impacts that its investment decisions may have on sustainability factors.

Kindly contact Bjorn Grech for a full copy of our ESG Policy.

Alignment of Remuneration Policy with Sustainability Investments

The Remuneration Policy of Altarius does not encourage risk-taking which is inconsistent with its risk profile as well as the risk profiles of the Funds under management.  Moreover, and in line with the AIFM’s Remuneration Policy, no variable remuneration is paid to staff unless it is determined to be justified following a performance assessment based on quantitative (financial) as well as qualitative (non-financial) criteria.  

Considering the limited impact of variable remuneration of identified employees on the risk profile of the Company’s clients and the nature of the business of the Company (including, where applicable, the delegation of the investment management function to other third-party entities), the Company deems that there is no risk of misalignment with the integration of any sustainability risks in the investment decision making process of the Company in respect of its clients. Furthermore, the AIFM is of the view that its existing structures are sufficient to prevent excessive risk-taking in respect of any sustainability risks.



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