Important Notice

The website disclosures (the “Disclosures”) are being made pursuant to Articles 4(1) and 10(1) of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (as amended) (“SFDR”) in respect of Gresham House Forestry Fund I (Ireland) LP (the “Partnership”).

The Disclosures do not constitute (a) an offer of securities or interests, (b) an offer or invitation to the public, or (c) an invitation to apply for securities or interests. The Disclosures are being made to enable Gresham House Asset Management Limited, in its capacity as portfolio manager of the Partnership (the “Portfolio Manager”) to comply with its obligations under applicable law.

Sustainability statement

As a signatory to the UN-supported Principles for Responsible Investment, the Portfolio Manager has a clear commitment to investing sustainably as an integral part of its business strategy. Sustainability including Environmental, Social and Governance (ESG) considerations, are integrated into the selection, evaluation, governance and management processes across the lifecycle of each investment of the Partnership.

Forestry investments sourced and managed by the Portfolio Manager for the Partnership are very long-term and the Portfolio Manager sets out to proactively improve the lifespan and value of such assets of the Partnership through sustainable forest management.

Environmental and social characteristics

All land and forests acquired by the Partnership will be managed in line with the commitments and targets made in the Portfolio Manager’s Forest Charter (the “Charter“) (see “1. The Gresham House Forest Charter” below).

All land and forests acquired by the Partnership will be managed by Coillte, and all will be certified under the FSC® ¹ (Forest Stewardship Council®), and PEFC™ (Programme for the Endorsement of Forest Certification) and will continue to be independently certified as 100% sustainable pursuant to the relevant certification during the period that the Partnership owns them (with the exception of newly acquired land, which may not yet be certified at the time of purchase but in respect of which the Portfolio Manager will aim to ensure that 100% of forests thereon will be certified within a reasonable timeframe).

The table below sets out the key sustainability-related commitments of the Partnership and how these will be measured and monitored over time (many of which are also set out in the Charter).
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Sustainable investment process and commitments

The integration of sustainability considerations, including ESG factors, into the investment decision-making process followed in respect of the Partnership is underlined by the following:

1. The Gresham House Forest Charter

All forestry assets of the Partnership will be assessed at pre-investment stage and managed in line with the Charter unless any legal, regulatory, or natural obstacles outside the control of the Portfolio Manager prevent this. The Charter sets out the Portfolio Manager’s commitments and targets in relation to sustainable forest management, based on international forestry standards, and the key performance indicators against which performance can be measured.

The Charter includes commitments and targets relating to the following categories. All commitments are at least aligned with forest certification standards:

• Forest Products & Services
• Climate Change
• Biodiversity & Woodland Ecology
• Forest Protection
• Income & Employment
• Communities & People
• Forest Certification & Standards

The Charter also reflects the Portfolio Manager’s commitment to apply the International Finance Corporation (IFC) exclusion policy as relevant to forestry assets[1] (the “Exclusion Policy“) to all forestry investments of the Partnership. This means that the Partnership will not be invested in:

• production or activities involving harmful or exploitative forms of forced labour/harmful child labour;
• commercial logging operations for use in primary tropical moist forest;
• production or trade in wood or other forestry products other than from sustainably managed forests; or
• production or activities that impinge on the lands owned, or claimed under adjudication, by Indigenous Peoples (as defined by the IFC for the purposes of its exclusion policy), without full documented consent of such people.

These exclusions are explicitly built into the ESG Decision Tool (see next section) and require the Portfolio Manager to ensure that no new acquisition of the Partnership is in breach of the exclusions at due diligence stage.

[1] http://www.ifc.org/exclusionlist

2. The Portfolio Manager’s ESG Decision Tool

All investments are screened using the Portfolio Manager’s Forestry ESG Decision Tool (the “ESG Tool“) to ensure that ESG risks and opportunities are considered and the Exclusion Policy is applied, as part of sourcing, due diligence, acquisition, and ongoing management of assets.

The Porftolio Manager’s resources, tools and practices are proprietary given the complexity and nature of the asset class and are informed by its experience over the last 40 years. The ESG Tool and KPIs set out in the Charter, as developed by the Portfolio Manager, will assist it to identify potential sustainability risks and opportunities pertaining to the Partnership’s investments in a consistent manner, in line with the Portfolio Manager’s sustainability-related commitments.

The ESG Tool is based on the ten themes in the Portfolio Manager’s Sustainable Investment Framework and several sub-factors are considered under each broader ESG theme (see table below entitled “Sustainable Investment Framework Application”). The purpose of the ESG Tool is to support the Portfolio Manager in identifying potential, material ESG risks that need to be managed and mitigated, and to help shape the due diligence process prior to investment by the Partnership. The ESG Tool will highlight if an investment is considered to be in breach of the Exclusion Policy (in which case no investment will be made in that asset) and otherwise aims to provide a rational and replicable assessment of key ESG risks which should be considered prior to investment, and to assist with ranking the significance of each risk.

The data sources relied on for the consideration of ESG risks and opportunities pre-investment and as part of the ongoing management of assets include information provided by the Portfolio Manager’s own specialist investment team (see point 5 further below), the Woodland Manager and any other woodland managers appointed by the Partnership and/or third-party experts such as ecologists and carbon consultants (particularly in relation to biodiversity and carbon-related data).

Sustainable Investment Framework Application

3. Forest Certification and Standards

As committed to in the Charter, all forestry assets of the Partnership will adhere to relevant forestry standards and will be certified to appropriate sustainable forest certification standards. These standards provide detailed guidance on the principles that the Portfolio Manager adheres to in planning, management, felling and restocking cycles as well as the wider way in which forest enterprises are managed.

In Ireland, forests are certified under the PEFC (Program of the Endorsement of Forest Certification), or the FSC (Forest Stewardship Council) standards. The Portfolio Manager commits to ensuring that all forestry assets of the Partnership are ultimately certified under one of these methodologies and aims to seek dual certification across the entire portfolio of such assets.
Irish forestry assets will be managed in accordance with the Forestry Standards Manual in conjunction with the Irish National Forest Standard, the code of Best Forest Practice – Ireland and the suite of mandatory environmental guidelines and requirements published by the Department of Agriculture, Food and the Marine.

4. Management plans

Management plans are drawn up for each asset of the Partnership, setting out clear management objectives spanning both commercial and sustainability outcomes and how the asset will be managed to meet these within its given prevailing conditions. Performance measurements are integrated into the plans, which are subsequently reviewed on an annual basis.

The management plans will include plans to meet the Partnership’s sustainability commitments and to address any sustainability-related risks or opportunities identified from the ESG Tool analysis and will align to relevant standards or certification requirements.

5. Expertise and oversight

The Portfolio Manager has significant specialist expertise, including professional qualifications from the Institute of Chartered Foresters, spanning both sustainable forestry practices and sustainable investment. The team undertakes regular relevant continuing professional development to keep its knowledge and outlook up to date and will continue to invest in developing its expertise and good practice in relation to sustainable forestry asset management. External experts (e.g. ecologists and academics) may also be consulted by the Portfolio Manager in this regard.

All forests and new planting sites acquired by the Partnership will be managed by qualified, experienced forest managers, known to and selected by the Portfolio Manager. All forests are inspected on a regular basis to ensure the highest quality of woodland and environmental management. Forests will also be independently audited by the relevant certification bodies.

The Portfolio Manager has a dedicated Sustainable Investment Team. This team provides support in relation to the evolution of processes around sustainable investing applied by the Partnership. The Sustainable Investment Team will also carry out regular auditing of ESG processes to ensure they meet the sustainability-related commitments of the Partnership.

Mandatory SFDR disclosures

Assessment of Principal Adverse Impacts of Investment Decisions on Sustainability Factors

The Portfolio Manager has elected to exercise its discretion under Article 4(1)(b) of SFDR not to commit to considering the adverse impacts of investment decisions of the Partnership on sustainability factors in the manner specifically contemplated by Article 4(1)(a) of the SFDR but will continue to consider and manage these impacts in line with the Charter and its Sustainable Investment Policy.

Taxonomy Regulation

The investments underlying the Partnership do not take into account the EU criteria for environmentally sustainable economic activities, as set out in the Taxonomy Regulation. Accordingly, 0% of the Partnership’s investments are in economic activities that qualify as environmentally sustainable under the Taxonomy Regulation. Based on a high-level assessment, it is expected that, in pursuing their environmental characteristics or objectives, the Partnership’s investments will contribute to the following environmental objectives as set out in the Taxonomy Regulation: climate change mitigation and climate change adaptation. The “do no significant harm” principle applies only to those investments underlying the Partnership that take into account the EU criteria for environmentally sustainable economic activities. As set out above, the Partnership’s investments do not currently take into account the EU criteria for environmentally sustainable investments.

Supplementary Prospectus >>

Adverse sustainability impacts

Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”), the Fund is not classified as an Article 8 or Article 9 fund, however, disclosure in accordance with the requirements of Article 6 of SFDR in relation to the integration of sustainability risks, which is applicable to the Fund, is set out in the Prospectus. The Fund does not consider adverse impacts of investment decisions on sustainability factors, as defined under SFDR, as it is not required to do so under Article 4(3).

EU Taxonomy

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Supplementary Prospectus >>

Adverse sustainability impacts

Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”), the Fund is not classified as an Article 8 or Article 9 fund, however, disclosure in accordance with the requirements of Article 6 of SFDR in relation to the integration of sustainability risks, which is applicable to the Fund, is set out in the Prospectus. The Fund does not consider adverse impacts of investment decisions on sustainability factors, as defined under SFDR, as it is not required to do so under Article 4(3).

EU Taxonomy

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Supplementary Prospectus >>

Adverse sustainability impacts

Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”), the Fund is not classified as an Article 8 or Article 9 fund, however, disclosure in accordance with the requirements of Article 6 of SFDR in relation to the integration of sustainability risks, which is applicable to the Fund, is set out in the Prospectus. The Fund does not consider adverse impacts of investment decisions on sustainability factors, as defined under SFDR, as it is not required to do so under Article 4(3).

EU Taxonomy

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Supplementary Prospectus >>

Adverse sustainability impacts

Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”), the Fund is not classified as an Article 8 or Article 9 fund, however, disclosure in accordance with the requirements of Article 6 of SFDR in relation to the integration of sustainability risks, which is applicable to the Fund, is set out in the Prospectus. The Fund does not consider adverse impacts of investment decisions on sustainability factors, as defined under SFDR, as it is not required to do so under Article 4(3).

EU Taxonomy

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Supplementary Prospectus >>

Summary

The Gresham House Thematic Multi Asset Fund is managed through a top-down asset allocation framework which involves the formation of a house view on financial markets that drives the asset allocation. Individual asset allocation decisions are based on bottom-up fundamental analysis and application of a sustainable investment process.

The fund promotes environmental and social characteristics by investing at least 70% of its value in “sustainable assets”, as well as not investing in companies which do not adhere to global norms on environmental protection, human rights, labour standards and anti-corruption, and excluding companies which have significant involvement in certain industries. “Sustainable assets” are defined as those which meet the fund’s sustainable thematic alignment and exclusion criteria. Thematic alignment will be determined by the percentage revenue, or equivalent metric relevant to the business model, which demonstrates contribution to a sustainable theme. Investments must demonstrate that more than 20% of revenue, or equivalent metric, contributes to a sustainable theme to be included in the fund. The fund will report on the percentage of holdings aligned to each theme on a periodic basis.

In order to ensure the securities in the fund adhere to global norms and do not invest in excluded industries, an external ESG data provider is employed to monitor the portfolio. The internal investment team is responsible for compiling a sustainable investment thesis for each asset. The thesis includes a summary of findings from the ESG Decision Tool, employed to assess material ESG risks and opportunities, and an assessment of the thematic alignment of the underlying security.

No sustainable investment objective

This financial product promotes environmental or social characteristics but does not have as its objective a sustainable investment.

Environmental or social characteristics

The fund promotes environmental and social characteristics by investing at least 70% of its value in sustainable assets. “Sustainable assets” are defined as those which align to sustainable themes, including but not limited to Climate & Energy, Waste, Circular Economy and Food & Agriculture, and meet the fund’s exclusion criteria restricting investment in certain activities. The fund will also not invest in companies which do not adhere to global norms on environmental protection, human rights, labour standards and anticorruption.

Investment strategy

The Gresham House Thematic Multi Asset Fund seeks to achieve long-term capital appreciation with moderate risk exposure by investing on a diversified basis in transferable securities, such as equity securities and debt securities, and in collective investment schemes. The Fund may invest across asset classes, sectors, geographies, and market capitalisations without limitation save in respect of the restriction on investment that do not meet the fund’s thematic and exclusion criteria described below.

The Gresham House Thematic Multi Asset Fund is managed through a top-down asset allocation framework which involves the formation of a house view on financial markets that drives the asset allocation. Individual asset selection decisions are based on bottom-up fundamental analysis, including a consideration of valuation and business quality, as well as alignment to sustainable themes and adherence to exclusion criteria.

Exclusion criteria

All investments must pass a screening process carried out by a third-party data provider to ensure they meet the fund’s exclusionary criteria. Exclusionary criteria are twofold:

First, the fund precludes investment in companies which do not adhere to global norms on environment protection, human rights, labour standards and anti-corruption. Global norms include:

• OECD Guidelines for Multinational Enterprises
• ILO Tripartite Declaration of Principles concerning Multinational Enterprises and Social Policy
• UN Global Compact
• Guiding Principles on Business and Human Rights

The third-party data provider will produce a red flag for investments considered to violate these Norms. Investments receiving a red flag cannot be invested in or will be sold within three months if already invested.

Secondly, the fund excludes investments with significant involvement in certain industries and activities. The industries or activities and exclusion thresholds are listed below:

• Military Equipment Services and Production >10% revenue
• Gambling >10% revenue
• Pornography > 5% revenue
• Tobacco > 10% revenue
• Nuclear Power >10% revenue
•  Abortifacients – any involvement in Production, Distribution, Services
• Abortion Services/Planned Parenthood – any involvement
• Contraceptives – any involvement in Production, Distribution, Services
• Stem Cell Research – any involvement
• Alcohol Production – > 10% Revenue
• Fossil Fuels Production and/or Exploration >10% Revenue

Any investment that is determined by the third-party data provider to breach the thresholds will be sold from the portfolio within three months.

Thematic alignment

For all new investments made by the fund (except for cash or cash equivalents, or sovereign bonds), a company note including an investment and sustainability thesis must be produced prior to investment. This includes an analysis of the thematic alignment of the security and includes detail such as the theme targeted and a description of how the asset aligns to the theme.

All investments made by the fund must also be assessed using the ESG Decision Tool (“the Tool”) prior to investment. This tool is used to assess material sustainability risks and opportunities to the investment case and to identify any areas to be monitored and addressed through engagement and/or voting, as and when relevant, through the holding period. A summary of material findings from the Tool will be included in the company note.

Good governance

Good governance is assessed through application of the Tool which prompts an assessment of sustainability risks and opportunities to the investment case under the headings noted below:

• Board structure, composition and protocols
• Board skills and engagement, including in ESG risk
• Delivering change and success
• Anti-competitive behaviour
• Anti-bribery & corruption
• Ethical risk profiling and management

It is also considered that the exclusion of investments in breach of global norms contributes to the avoidance of investments that do not demonstrate good governance.

Sovereign bonds

Investment in sovereign bonds does not apply the fund’s exclusion or thematic alignment criteria. Investments in sovereign bonds that are intended to be held for more than 12 months (i.e. those that are not considered cash or cash equivalents) will be required to have a prime ESG rating (B- or above), as defined by a third party ESG data provider.

Proportion of investments

The fund invests across a variety of asset classes including equities, cash, bonds, property and alternative assets such as infrastructure and forestry. The fund will invest at least 70% of fund value in assets that promote environmental and social characteristics as determined by their alignment to sustainable themes and compliance with the fund’s exclusion criteria.

Up to 30% of the fund asset value is classified as “other”. This mainly consists of investments in cash and/or bonds. This allocation is necessary from an asset allocation perspective

The fund does not intend to make any sustainable investments.

Monitoring or environmental or social characteristics.

1. Continuous monitoring is carried by an external ESG data provider to ensure investments are not in breach of global norms in relation to environmental protection, human rights, labour standards and anti-corruption and to ensure that investments continue to meet exclusionary criteria.

2. Meetings with representatives of investments will be carried out regularly by the Gresham House Ireland Investment Team in order to:

• Assess the underlying investment thesis including alignment to sustainable themes
• Monitor any ESG specific risks identified
• Assess additional ESG risks
• Encourage improvements in ESG shortcomings

3. The Fund is overseen by the Gresham House Ireland Investment Committee on a regular basis who provide oversight of the fund’s adherence to the investment process detailed above.

Methodologies

To ensure an alignment of investments to sustainable themes, a sustainable investment thesis is compiled by the Investment Team which includes an analysis of thematic alignment as well as an assessment of ESG risks. The assessment of thematic alignment is based on bottom-up fundamental research.

An external provider is employed to ensure the global norms, exclusionary criteria and country ESG ratings of the fund are met. Please see here links to the:

• Methodology applied to assess adherence to global norms
• Methodology applied to determine revenue associated with exclusion criteria
• Methodology applied to assess country ESG rating

Data sources and processing

An external provider, currently ISS (Institutional Shareholder Services), is employed to provide data relating to compliance with global norms, breach of exclusion criteria, principal adverse impact indicators and country ESG ratings.

Internal analysis of all investments is conducted by the Gresham House Ireland Investment Team to determine thematic alignment. This is based on publicly available information and includes a review of documents including annual reports and sustainable investment reports, or equivalent.

Limitations to methodologies and data

Data relating to exclusions and global norms violations is provided by third party providers. The Manager is dependent on the external provider to provide accurate data. This data is also dependent on companies disclosing relevant data and accurate data.

The subjective nature of ESG data and sustainability topics means that third parties may not agree with the Investment Team or external provider in relation to thematic alignment or global norms violations.

Not all investments of the fund are covered by the third-party data provider. In circumstances where the investment is not covered, the Investment Team will endeavour, to an extent which is fair and reasonable, to follow the investment process laid out above using publicly available information. The Investment Team may also aim to improve on gaps in data by engaging with investments to encourage improved disclosure of required information.

Due diligence

To assess ESG risks associated with an investment, an internal ESG tool is applied by the investment team. In order to ascertain the sustainability characteristics of the underlying assets, a sustainability investment thesis is compiled by the investment team.

The Gresham house Ireland Investment Committee provides oversight of the fund’s investment process. The Sustainable Investment Team also carries an annual audit to assess adherence of the Investment Team to sustainable investment related commitments including the completion of ESG Decision Tools.

Engagement policies

Engagement is part of the Manager’s sustainable investment approach, as detailed in the Engagement & Voting Policy. The Investment Team will engage with non-cash and non-government securities. The purpose of engagement can vary but includes to:

• Monitor any ESG risks identified, including controversies
• Encourage improvements in ESG shortcomings to enhance value of investments
• Assess alignment with fund themes and alignment thresholds
• Encourage greater disclosure of ESG-related information

In addition, the fund will vote all resolutions where possible. Voting for holdings in the fund are undertaken by ISS based on the ISS Sustainability Policy guidelines.

Designated reference benchmark

The fund does not designate a reference benchmark.

Supplementary Prospectus >>

Adverse sustainability impacts

Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”), the Fund is not classified as an Article 8 or Article 9 fund, however, disclosure in accordance with the requirements of Article 6 of SFDR in relation to the integration of sustainability risks, which is applicable to the Fund, is set out in the Prospectus. The Fund does not consider adverse impacts of investment decisions on sustainability factors, as defined under SFDR, as it is not required to do so under Article 4(3).

EU Taxonomy

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.