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SFDR Fund Classification
This fund promotes environmental (E) or social (S) characteristics in accordance with Article 8 of the Regulation (EU) 2019/2088. This fund does not have as its objective sustainable investment.
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This fund (“Fund”) promotes environmental or social characteristics, but does not have as its objective sustainable investment. However, the Fund commits to invest a minimum proportion in sustainable investments and thus ensures that those investments do not significantly harm any of the sustainable objectives by following Söderberg & Partners Asset Management S.A.’s (the “Company”) policy for responsible investments (“Policy for Responsible Investments”) found here.
As the Fund has a broad approach to responsible investments, it promotes a wide range of environmental and social characteristics, with a focus on supporting companies in their transition towards alignment with a selection of the United Nations Sustainable Development Goals (“SDGs”). The Company conducts responsible investments based on three principal pillars: exclusion screening, positive selection, and active engagement. Good governance practices are a precondition for the Fund’s investments. The process of managing the overall responsible investing activities is coordinated internally within the Söderberg & Partners Group, with an active input from the Company’s Responsible Investment Committee (“RI Committee”).
The Fund is expected to invest at least 75 % of its NAV in investments that qualify as aligned with environmental or social characteristics and at least 10 % of its NAV in investments that qualify as sustainable investments. The Fund is allowed to invest up to 25 % of its NAV in cash, cash equivalents, and/or hedging instruments.
In order to measure the attainment of each of the environmental and social characteristics promoted by the Fund, three sustainability indicators are used. These are monitored throughout the lifecycle of the fund through the application of the Company’s approach to responsible investing. This encompasses the application of exclusion filters in the portfolio construction process, as well as the utilization of a sustainability rating of funds, and a comparison of the principal adverse impact indicators (“PAIs”) for each investment.
The Company identifies sustainability factors through various means with data sources ranging from third-party data providers to internal analysts, and specialists in the field of sustainable investments, use of publicly available information, shared information from peer networks or direct engagements with the Fund’s investments. Where information relating to any of the environmental and social characteristics promoted by the Fund is not available, best effort is used for assessment.
The primary focus of the Fund’s investments is other funds (“Target funds”) and exchange traded derivatives. For these investments, the possibilities of shareholder engagement by voting are considered limited, as detailed in the Company’s policy for shareholder engagement (“Policy for Shareholder Engagement”) found here. However, the Company aims to increase the value of the Fund by showing engagement on sustainability issues in the underlying holdings through its responsible investing process.
No benchmark is used to determine the alignment of the Fund with the sustainability characteristics it promotes.
No sustainable investment objective
This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment. However, the Fund commits to invest a minimum proportion in sustainable investments.
The Company considers principal adverse impacts of its investments in the Fund on a look-through basis. The do no significant harm principle is thus principally applied by the Target funds on the portion of sustainable investments they make. However, to mitigate negative externalities, the Company has a process in place to ensure that Target funds follow its rules for the exclusion of companies in which they invest (“Investee companies”) as stated in the Policy for Responsible Investments (the “Screening process”). The Company also monitors whether the sustainable investments are aligned with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights through a norm-based screening incorporated in the Screening process. Moreover, the Company requires that Target funds take the PAIs of the companies in which they invest into account for the sustainable investments. In turn, the Company measures the PAIs of the Target funds on a look-through basis (the “PAI process”) as detailed in the Policy for Responsible Investments.
More information on how the Company ensures that the sustainable investments do not significantly harm any of the sustainable investment objectives is detailed in the Appendix for the Fund in the Prospectus found here.
Environmental or social characteristics of the financial product
In general, the Company has a broad approach to responsible investments and thus a wide range of environmental and social characteristics are promoted by this Fund. As the Fund is a fund-of-funds, the Company particularly focuses on the inclusion of funds with exposures to sustainable companies and on the engagement with those companies in order to continue to support them in their transition towards alignment with the SDGs which are prioritized by the Company (“Targeted SDGs”), found here. The Company has selected several PAIs to consider that correspond to the Targeted SDGs, which are detailed for the Fund in the Appendix of the Prospectus.
The Company’s view is that responsible investing is a requirement for long-term and sustainable value creation through integration of sustainability factors (i.e., environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters) to foster a positive change. The Company therefore has a strong commitment to invest responsibly, and environmental, social and governance (“ESG”) issues are considered in the investment decisions. The Company conducts responsible investments based on three principal pillars: exclusion screening, positive selection, and active engagement.
Exclusion screening: The Company’s main principle is to use its influence to bring about positive changes in its investments, rather than to exclude and divest. However, the Company conducts exclusion when the ability to influence the Target fund or Investee company to align its operations with the Targeted SDGs is limited, or when an investment does not show a willingness to comply with the Policy for Responsible Investments. The Company applies the same Screening and PAI processes as mentioned in the ‘No sustainable investment objective’ section above to manage this.
Positive selection: In the management of the Fund, the Company utilizes a sustainability rating of funds generated by another entity within the Söderberg & Partners group (“Sustainability rating”). The funds with a better Sustainability rating are preferred when selecting investments and the Fund shall not be invested in funds with a red Sustainability rating. More information on the Sustainability rating is available here. In addition, the Company’s consideration of ESG characteristics is verified through a sustainability questionnaire that is addressed to the managers of the Target funds. The Fund aims to primarily, where available, invest in funds with a sustainable investment objective. Secondarily, the Fund aims to invest in funds that promote environmental or social characteristics, or in funds that demonstrate improvements of these characteristics, resulting in improved Sustainability ratings.
Active engagement: The Company wants to encourage other fund managers and companies to be compliant with international norms and conventions and manage their business in a more sustainable manner. The Company will engage for positive outcomes with the ambition of aligning corporate outputs with improving ESG characteristics based on the Target funds Sustainability ratings, exclusion screening results, and alignment with the Targeted SDGs.
To assess good governance practices, the Fund excludes companies that are in breach of international norms and conventions, whilst including with respect to sound management structures, employee relations, remuneration of staff, and tax compliance. As aforementioned, the investments are aligned with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight fundamental conventions identified in the Declaration of the International Labour Organisation on Fundamental Principles and Rights at Work and the International Bill of Human Rights.
The process of managing the overall responsible investing activities is coordinated internally with an active input from the Company’s RI Committee. The RI Committee is responsible for the ongoing management of sustainability risks and operates in a both reactive and proactive way. Furthermore, the RI Committee develops and organizes work around responsible investing, including updating and overseeing related policies and procedures adhering to the ESG management, and keeps the organisation informed about developments relating to sustainability.
Proportion of investments
The Fund is expected to invest at least 75 % of its NAV in investments that qualify as aligned with environmental or social characteristics and at least 10 % of its NAV in investments that qualify as sustainable investments.
The Fund is allowed to invest up to 25 % of its NAV in cash, cash equivalents, and/or hedging instruments.
Monitoring of environmental or social characteristics
The sustainability indicators used to measure the attainment of each of the environmental or social characteristics promoted by the Fund are:
1- Percentage exposure of the Fund to the sectors excluded.
2- Percentage of the Target funds with a red Sustainability rating.
3- Percentage exposure of the Target funds with PAI indicators classified as Unresolved.
The environmental and social characteristics promoted by the Fund, as well as the sustainability indicators used to measure the attainment of these characteristics, are monitored throughout the lifecycle of the fund through the application of the Company’s three pillar investment strategy, detailed above.
Moreover, the Company’s approach to managing climate-related risks and opportunities is guided by recommendations of the Task Force on Climate-related Financial Disclosures (“TCFD”). The Company monitors the transition to a low-carbon society through yearly collections of the Fund’s carbon footprint by measuring the Weighted Average Carbon Intensity (WACI), the metric recommended by the Task Force. The full Climate Report, informed by the TCFD, can be found here.
The binding elements of the investment strategy used to select investments to attain each of the environmental or social characteristics promoted by the Fund are:
1- The application of the exclusion criteria (the Screening process).
2- The exclusion of Target funds with a red Sustainability rating.
3- The exclusion of Target funds with PAIs classified as Unresolved, and accordingly failing to align with the Targeted SDGs (the PAI process).
Screening process: The Company ensures that the Target funds follow the exclusion criteria stated in Appendix 1 of the Policy for Responsible Investments by conducting pre-investment and semi-annual screenings on the Investee companies using an internal tool based on data provided by external parties. The Company can accept deviations from the exclusion criteria if an Investee company is transitioning towards a more sustainable business. If an Investee company is flagged in a screening, the Company will discuss the Investee company’s progress with the Target fund, whereafter the matter is classified as Resolved, Transitioning (clear action plan to resolve the violation) or Unresolved (in violation of the exclusion criteria). If the investment is classified as Unresolved after the first assessment, it will be discussed with the Company’s RI Committee to determine the appropriate action that needs to be taken, as detailed below.
Sustainability rating: If a Target fund is downgraded to a red Sustainability rating, the Company will initiate a dialogue with the entity generating the Sustainability rating to understand why and engage with the management of the Target fund to see what they must do to improve. It is then discussed with the Company’s RI Committee to determine the appropriate action that needs to be taken, as detailed below.
PAI process: The Company requires that Target funds consider PAIs and uses an internal tool based on data provided by external data providers for measuring and comparing PAIs of the Target funds on a look-through basis, pre-investment and on an annual basis. If a Target fund shows deterioration of a considered indicator between measurements, the investment will be flagged. The Company will discuss the progress of the indicator with the Target fund, whereafter the flagged investment can be classified as Resolved, Transitioning (clear action plan to improve the indicator in place) or Unresolved (no action is taken or plan in place). If the investment is classified as Unresolved after the first assessment, it will be discussed with the Company’s RI Committee to determine the appropriate action that needs to be taken, as detailed below.
In addition to what has already been mentioned, the responsibilities of the RI Committee also include decision-making regarding the assessment of companies in relation to the binding elements of the Fund’s investment strategy. The RI Committee discusses the Target funds and Investee companies based on the indicative results from the Screening and PAI processes, as well as any Target funds with downgraded Sustainability ratings. The RI Committee focuses on Target funds and Investee companies that can be influenced to apply a more sustainable solution so that they are not in violation of the Policy for Responsible Investments. Should the monitoring show that the management of a Target fund is not sufficiently addressing a potential violation within one year of first being identified, i.e., no progress is made, or no action plan is in place, the Fund shall divest.
Data sources and processing
The Company identifies sustainability factors through various means, including the Screening and PAI processes, based on the information collected from the third-party data provider Sustainalytics, a Morningstar company. In turn, Sustainalytics collects information from publicly available reports published by the companies, through direct contact with the companies, and from media.
The Company may also utilize information from other service providers, internal analysts, and specialists in the field of sustainable investments, use publicly available information, shared information from peer networks or engage directly with the Target fund managers or the management of companies.
Where information relating to any of the environmental and social characteristics promoted by this Fund is not available, best effort is used for assessment, including a description of any reasonable assumptions made, cooperation with third-party data providers, or use of external experts.
Limitations to methodologies and data
The implementation of the Policy for Responsible Investments may limit the number of investment opportunities available to the Fund, which may affect its performance compared to other funds that do not employ such investment policies. The integration of investments which maintain strong ESG credentials may result in a return that at times compares unfavourably to similar products without such focus. Moreover, responsible investing is mainly qualitative and subjective by nature, and there is no guarantee that the criteria utilized, or judgment exercised by the Company will reflect the beliefs or values of any particular investor.
The Fund obtains information about the Investee companies from Sustainalytics, Morningstar, third-party analysis, and through its own internal analysis. The Fund cannot, however, guarantee that the sustainability information obtained is always complete and correct. As information can be obtained from many different data sources, it is not expected that such limitations affect the attainment of the environmental and social characteristics promoted by the Fund.
The Company has a comprehensive approach to manage sustainability risks associated with the Fund. A due diligence is carried out on the investments of the Fund through the responsible investing approach consisting of exclusion screening, positive selection, and active engagement which identifies and addresses related risks. Furthermore, the fund managers’ work to manage sustainability risks is considered and integrated in the Sustainability rating. Lastly, the Company’s approach to managing climate-related risks and opportunities is guided by the recommendations of TCFD. This risk management is employed in investment decisions, products, policy developments, and in engagements alike.
The primary focus of the Fund’s investments is other funds and exchange traded derivatives. For these investments, the possibilities of shareholder engagement by voting are considered limited. However, the Company shall take an active and responsible role as an investor. In the role as investor, the Company shall always aim for long-term values with emphasis on sustainability, activity, and responsibility. The investments in the Fund are continuously monitored by the Company with respect to ESG factors. The Fund will not invest in other funds with severe or systematic ESG controversies. Moreover, the investment in other funds should follow the Company’s Policy for Responsible Investments and should not be made if the Fund deems that the funds are not likely to address problematic issues identified in the PAI and/or Screening process within an acceptable amount of time. The level of engagement with the Target funds varies and depends, for example, on the size of the Funds’ holding and anticipated improvements.
Additional information is available in the Company’s Policy for Shareholder Engagement.
Designated reference benchmark
An index has not been designated as a reference benchmark to meet the environmental or social characteristics promoted by the Fund.
Implementation of EU Regulation 2022/1288 supplementing Regulation (EU) 2019/2088 with regard to regulatory technical standards, RTS.
Implementation of EU Regulation 2020/852 on the establishment of a framework to facilitate sustainable investment and amending the EU Regulation 2019/2088, the EU Taxonomy.
Implementation of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector, SFDR.
The information should only be seen as general information and should not be construed as investment advice or recommendations. Söderberg & Partners Asset Management shall not be held liable in relation to shareholders or third parties for any loss that may be derived from the fund. Investments in funds involve financial risks which is the responsibility of the investor to bear.