SFDR disclosures

The European Union’s Sustainable Finance Disclosure Regulation (SFDR) has come into force requiring, amongst other things, asset managers to make certain sustainability-related disclosures on their websites with respect to in-scope products.

Gresham House Asset Management Limited

Below are links to the website disclosures of all in-scope products under the management of Gresham House Asset Management Limited. Note that the website disclosures of one in-scope product will differ from those of another in-scope product.

Gresham House Asset Management Ireland Limited

Entity-level SFDR Disclosures

Under the EU Sustainable Finance Disclosure Regulation (SFDR), Financial Market Participants (FMPs) are required to make sustainability-related disclosures on their websites. This section provides disclosures required under the SFDR.

Sustainability Risk Policies

At Gresham House, we have developed a clear sustainable investment policy and are working hard to embed our approach consistently and effectively in line with our commitments, aiming to always be best in class.

Group Sustainable Investment Policy

 

The Gresham House Group Sustainable Investment Policy is applicable to Gresham House Asset Management Ireland Limited (Gresham House Ireland).

Across all our asset classes, we believe that understanding and, wherever possible, improving on environmental, social, economic and governance (ESG) performance drives long-term value, and we aim to work proactively with management teams and key stakeholders to make a positive change over time.

Our asset class policies

The Gresham House, Ireland Sustainable Investment Policy describes the sustainable investment commitments of the Manager1 for all unit trusts2.

1. The Manager refers to Gresham House Asset Management Ireland Limited (Gresham House Ireland), the Alternatives Investment Fund Manager (AIFM)

2. A Unit Trust is an arrangement made for the purpose of providing facilities for the participation by the public, as beneficiaries under a trust, in profits or income arising from the acquisition, holding, management or disposal of securities or any other property.

Gresham House, Ireland Sustainable Investment Policy

The Gresham House Commercial Real Estate Sustainable Investment Policy describes the sustainable investment commitments of the Manager1 for the Gresham House Commercial Property Fund.

1. The Manager refers to Gresham House Asset Management Ireland Limited (Gresham House, Ireland), the Alternatives Investment Fund Manager (AIFM)

Sustainability Risk Integration

The Manager integrates sustainability risks as part of its investment decision-making process for all funds.3 The Manager believes that incorporating sustainability factors into investment decision making protects value and drives resilience of investments and can create compelling investment opportunities.

3. A sustainability risk integration model is currently being developed in respect of the Gresham House Commercial property fund.

A sustainability risk is an ESG event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment. The likely impacts of sustainability risks on the returns of the fund will depend on the fund’s exposure to investments that are vulnerable to sustainability risks and the materiality of the sustainability risks.

The integration of sustainability risk throughout the investment lifecycle is key to the overall success of the funds under management. Sustainability risk assessment is part of the pre-investment due diligence process carried out by Investment Teams. Investment Teams are required to analyse how certain ESG factors may impact the investment case and the fund Net Asset Value. This is done through the application of the ESG Decision Tool (‘the Tool’).

The Tool is a key component of Gresham House’s approach to ESG integration and is applied by all investment divisions. The Tool aims to support the identification of a broad range of ESG risks which may materially impact on a proposed transaction. It does so by prompting a consideration of various aspects underlying ten core ESG themes laid out in the Sustainable Investment Framework. These themes include but are not limited to Governance & Ethics, Marketplace Responsibility, Climate Change and Pollution, Supply Chain Management and Employment, Health, Safety & Wellbeing.

The Tool will not tell the investment teams whether to invest or not, instead it aims to provide a rational and replicable assessment of key ESG risks which should be considered prior to investment, and to help rank the significance of each risk. The Tool also provides a way of summarising material ESG issues, which can then be tracked and monitored over time, and include actions that can be taken to mitigate those risks throughout the holding period.

The findings from the tool can be used to identify topics to engage investments , with the aim of increasing shareholder value over time and reducing downside risk. The findings may also drive voting decisions as a means of managing risk identified, if relevant to the investment strategy.

Adverse impacts of investment decisions on sustainability factors

Adverse impacts of investment decisions on sustainability factors are not considered by Gresham House, Ireland (the Manager) and the Manager does not intend to consider adverse impacts for its investment strategies as it is not required to do so under the SFDR Article 4.

At product level, it is our belief that the consideration of sustainability risks through ESG integration, as defined in the Gresham House Ireland Sustainable Investment Policy, is sufficient to demonstrate a consideration of sustainability risks and impacts for funds which do not have sustainable investment as their objective.

Remuneration policies

Sustainable investment-related objectives form part of employee variable remuneration review as detailed in Gresham House Asset Management Ireland Limited’s (Gresham House, Ireland) Remuneration Policy.

This extract is a carve out of the Gresham House, Ireland’s Remuneration Policy for the purpose of investor awareness and SFDR compliance.

Gresham House, Ireland is authorised by the Central Bank of Ireland as an Alternative Investment Fund Manager pursuant to the European Union (Alternative Investment Fund Managers) Regulations, 2013.

Variable Remuneration

Performance management is measured by senior management on both a quantitative and qualitative basis with performance evaluations taking place on a mid-year and an annual basis. Employees may be eligible for a discretionary annual bonus payment. The level of bonus will depend on the performance of the individual, the Investment Team as a whole and the overall firm performance and takes into account financial as well as non-financial criteria. Gresham House, Ireland gives appropriate consideration to financial and non-financial criteria, including performance against sustainable investment-related objectives.

The annual bonus payment is at the total discretion of the firm. To reinforce the emphasis on sustainability, the firm not only considers what was achieved, but how the results were achieved when deciding on variable remuneration.

The Gresham House, Ireland remuneration principles are designed to attract a diverse and talented workforce, align reward with consideration of risk factors and support appropriate and controlled risk taking in line with fund objectives and strategies.

 

Product-level Sustainability-related Disclosures

Under the SFDR, Financial Market Participants (FMPs) are required to make certain sustainability-related disclosures on their websites with respect to investment products. Below are links to the website disclosures of all in-scope products under the management of Gresham House, Ireland. Note that the website disclosures of one in-scope product will differ from those of another in-scope product.