Sustainability risk
Sustainability risks are uncertain environmental, social or governance-related events or conditions that, if they occur, can cause a significant negative impact on the company and other participants.
Sustainability related disclosures
1. Introduction
R+V AIFM S.à r.l (hereinafter “the AIFM” or “R+V”) is licensed as an alternative investment fund manager in accordance with the Luxembourg Law of July 12, 2013 on alternative investment fund managers (hereinafter “AIFM Law”) and supervised by the Luxembourg supervisory authority Commission de Surveillance du Secteur Financier (hereinafter referred to as “CSSF”)
As part of its regulatory authorization, the AIFM manages funds that are classified as alternative investment funds (“AIF”).
1.1 Sustainability-related disclosure obligations in the financial services sector
On November 27, 2019, Regulation (EU) 2019/2088 of the Council and European Parliament was published, defining and requiring sustainability-related disclosure requirements in the financial services sector (hereinafter “SFDR”), which came into force on March 10, 2021.
The main goal was transparency,
- how sustainability risks are taken into account in the management of investment funds and,
- whether the main adverse impacts of investment decisions on sustainability factors are taken into account in the management of investment funds (“comply or explain”).
In principle, these transparency requirements apply to both the AIFM and the Alternative Investment Funds (“AIFs”) under management.
2. Aim of the directive
This guideline explains the decision of R+V with regards to the consideration of the main adverse impacts of investment decisions on sustainability on sustainability factors (hereinafter referred to as “PAIs” or “principal adverse impacts”) in the management of the AIFs in accordance with the requirements of Article 4 (1) SFDR.
3. PAIs
The AIFM has decided not to consider principal adverse impacts (PAIs) in the investment decision‑making process of the AIFs or at AIFM level. Consequently, the AIFM does not publish a PA(S)I Statement.
At present, the structured and reliable data required for assessing and reporting PAIs is not sufficiently available. As a result, the AIFM is currently unable to prepare the corresponding disclosures or reports.
The AIFM continuously monitors regulatory developments, data availability and internal requirements. Should a decision by the AIFM or its Board of Managers, a mandatory regulatory change, or a R+V Group requirement necessitate the definition, implementation or disclosure of PAIs, the AIFM will take timely and appropriate action.