Sustainable Finance Disclosure Regulation
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”) seeks to (i) establish a harmonised approach in respect of sustainability – related disclosures made by financial market participants to investors within the European Union’s financial services sector and (ii) to achieve more transparency regarding how financial market participants integrate sustainability risks into their investment decisions and the consideration of adverse sustainability impacts into the investment process. Financial market participants include AIFMs, MiFID authorised firms and UCITS management companies, in their capacity as manager of financial products (which includes all forms of AIFs, UCITS and/or segregated client accounts).
For the purposes of SFDR, Cardinal Capital Group Unlimited Company (“Cardinal”) is a financial market participant.
Integration of Sustainability Risks
Cardinal integrates the consideration of sustainability risks into its decision making process for the financial products under management. Unless otherwise specified in the offering document for the relevant financial product under management, Cardinal’s ESG Policy applies to Cardinal and all financial products and entities currently managed by Cardinal.
Cardinal’s ESG Policy sets out Cardinal’s approach to integrating the consideration of ESG issues and sustainability risks throughout the investment cycle, including in the course of its investment due diligence process, the investment committee approval process, and the monitoring of financial products investments and post-investment.
Assessment of the Impact on Likely Returns
An assessment of the impact of sustainability risks on the financial products’ returns has been undertaken by Cardinal. Following the results of the assessment and having considered the composition of the assets of the portfolio and the investment objective and policies of the financial products, the impact of sustainability risks are not likely to have a material impact on the returns of the financial products.
Remuneration Considerations
Cardinal has adopted remuneration policies consistent with its obligations under the European Union’s Alternative Investment Fund Managers Directive 2011/61/ EU (“AIFMD”). Cardinal’s remuneration policies (i) promote sound and effective risk management and (ii) discourage excessive risk taking, including without limitation, with respect to sustainability risks. A sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.
The assessment of Cardinal’s staff performance is based on a multi-year framework in order to take into account the long-term performance of staff, as well as the performance of the financial products under management. Performance objectives are therefore a multi-year process, ensuring that staff and end investors’ interests are aligned.
Variable remuneration is dependent upon the performance of the business unit, the performance of Cardinal and the performance of the individual concerned. This serves to discourage excessive risk taking, as no one individual can influence Cardinal’s performance. The determination of an individual’s entitlement to variable remuneration will take into account the individual staff member’s performance in the relevant performance period taking into consideration both financial and non-financial criteria. As part of the measurement of performance used to calculate variable remuneration this will include the consideration of relevant types of current and future risks, including sustainability risks.
Adverse Sustainability Impacts Statement — Consideration of Principal Adverse Impacts
Given the investment strategy of the financial products and the asset classes of the financial products, Cardinal does not currently consider the adverse impacts of its investment decisions on sustainability factors. Should there be a change in the investment strategy of the financial products or the type of asset classes of the financial products this may be reconsidered by Cardinal.
Updated September 2023