Sustainability-related disclosures

      Sustainability Risk Policy Statement

      Background and Scope

      Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“the SFDR”), is part of a broader legislative package under the European Commission’s Sustainable Finance Action Plan. The SFDR requires firms to make strategic business and policy decisions regarding their approach to ESG which must be disclosed on the firm’s website and in pre-contractual and periodic disclosures. ESG stands for ‘Environmental, Social and Governance’ and covers a number of areas, including: climate, energy use, availability of raw materials, health, security, human rights, labour laws, and corporate governance.

      The SFDR applies at the firm level, to “Financial market participants (FMP)” which includes AIFMs, UCITS management companies, MiFID investment firms, and the product level (or “Financial products (FP)” as defined within the SFDR.

      Article 3 of the SFDR, requires a financial market participant to ”publish on their websites information about their policies on the integration of sustainability risks in their investment decision‐making process.” Waystone (being those entities listed in Appendix 1 below) have adopted this statement to describe the approach taken to demonstrate compliance with Article 3 of the SFDR. The Waystone Entities also have specific entity level Policies which are linked hereunder.

      Integration of sustainability risks

      Waystone acknowledges the impacts that sustainability risks can impose on the funds managed and considers the approach to integrate the risks stemming from sustainability issues described in this policy as strengthening its fiduciary duties towards the investors of the funds managed.

      Detailed entity specific information on Waystone’s approach to integrate sustainability risks into the investment decision making process can be found in the dedicated policy which has been set-up in compliance with the requirements, which is available here.

      Principle adverse impact (PAI) statement

      For the time being Waystone does not consider adverse impacts of investment decisions on sustainability factors. In accordance with Art. 4 I b of the SFDR, the main reason for not considering adverse impacts of investment decisions on sustainability factors at the company level is the lack of further information and data available to adequately assess the principal adverse impacts.

      As Waystone mainly cooperates with duly authorized external portfolio managers being located in one of the member states of the EU who may already consider principle adverse impacts on their investment decision for the funds (or sub-funds thereof) they manage; further information may be found in each Fund’s relevant documentation (i.e. in the Fund’s Prospectus or the Fund’s Private Placement Memorandum as applicable), which can be found on the website of the specific external portfolio manager.

      However, in the case where Waystone cooperates with duly authorized external portfolio managers not located in one of the member states of the EU, further information with respect to the principal adverse impacts of their investment decisions on sustainability factors might not be available on their website.

      Remuneration policy

      The SFDR requires financial market participants to integrate information on the consistency of their remuneration policy with the integration of sustainability risks, in accordance with Art. 5 I of the SFDR.

      Waystone has amended its remuneration policy accordingly. Additional information for each of the Waystone entities can be found here.

      Pre-contractual information

      All required information at a product level can be found in the specific pre-contractual information of the product (e.g. sales prospectus; private placement memorandum).

      Appendix 1:

      Waystone Management Company (IE) Limited
      Waystone Management Company (IE) Limited – Luxembourg Branch
      Waystone Fund Management (IE) Limited
      Waystone Asset Management (IE) Limited
      Waystone Investment Management (IE) Limited
      Waystone Management Company (Luxembourg) S.A.