Environmental, Social and Governance Disclosure

Responsible and Sustainable Investing

The Company currently does not integrate sustainability risks, as defined under Article 2(22) of Regulation (EU) 2019/2088, into its investment decision-making process. Given the nature, scale and complexity of its activities, the Company considers such risks not to be relevant to its investment approach at this time. Accordingly, sustainability risks are not expected to have a material impact on returns.

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 ongoing basis. In such cases, we 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 at recommending / and or investing in such products on an ongoing basis, in so far as applicable.

Exclusions

We will not knowingly invest in entities involved in the following activities:
– arms manufacturing;
– manufacture of tobacco;
– hard spirits;
– gambling; and
– genetically modified organisms.

We will assess these types of investments on a case-by-case basis, and any potential for indirect exposure is carefully considered and factored into investment selection.

Principle Adverse Impacts

The Company does not currently consider principal adverse impacts of investment decisions on sustainability factors within the meaning of Article 4 SFDR. This decision reflects the nature, scale and complexity of the Company’s activities and the limited availability of reliable sustainability data across relevant investments. The Company will keep this position under periodic review.

Kindly contact Operations@mansardcm.com for a full copy of our ESG Policy.

Alignment of Remuneration Policy with sustainability investments

In line with our Remuneration Policy, no variable remuneration is paid to our staff unless it is determined to be justified following a performance assessment based on quantitative (financial) as well as qualitative (non-financial) criteria.

Due to this very limited impact on the risk-profile of our clients, as well as the nature of our business, we deem that there is no risk of misalignment with the integration of the sustainability risks, if any, in our investment decision-making process with respect to our clients / investment recommendations given to our clients.

As such, we believe that our existing structures are sufficient to prevent excessive risk taking in respect of sustainability risks, if any.