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Luxembourg AIFM – sustainability related disclosures

(Status: 28.12.2023)

Intertrust Fund Management (Luxembourg) S.à r.l. (the Company) is a management company pursuant to Chapter 16 of the Law dated 17 December 2010 relating to undertakings for collective investment and acts as an alternative investment fund manager (AIFM) pursuant to Chapter 2 of the Law dated 12 July 2013 on alternative investment fund managers.

The AIFM qualifies as a financial market participant under 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), as amended from time to time.

As such, the Company is required to publish a disclosure on its website regarding how sustainability risks are integrated in its investment decisions-making process and oversight duties.

Article 3 SFDR disclosure

The AIFM as a third-party management company is fully committed to having a sustainable investment approach for its investments when required by the investment advisor (Investment Advisor) or delegated portfolio manager (Delegated Portfolio Manager) in relation to the investment strategy applied to each fund or sub-fund that promote environmental or social characteristics (Article 8 SFDR) or have sustainable investment as an objective (Article 9 SFDR). The AIFM makes sure that all the policies and procedures of the Investment Advisor or Delegated Portfolio Manager subject to the integration of sustainability risk within the investment process are disclosed on their website.

For product-level sustainability-related disclosures, please refer to the relevant website of Article 8 and Article 9 AIFs listed below:

Article 8 SFDR classified AIFs:

Article 4 SFDR disclosure

The AIFM, according to Article 4 of SFDR, ensures that its website and Delegated Portfolio Manager and Investment Advisor websites provide transparency for:

  • Considering or not considering principal adverse impacts of investment decisions on sustainability factors
  • Information about policies on the identification and prioritization of principal adverse sustainability impacts and indicators
  • Adverse sustainability impacts
  • Engagement policies
  • Responsible business conduct

Article 5 SFDR disclosure

The AIFM, in accordance with Article 5 of SFDR, aims and ensures that its Delegated Portfolio Manager and Investment Advisor include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks and shall publish that information on their websites.

Article 10 SFDR disclosure

The AIFM, functioning as a third-party management company, provides solutions to funds and sub-funds that endorse environmental and social characteristics or have sustainable investment as their objective. The following information is disclosed:

a) Description of the environmental or social characteristics or the sustainable investment objective.

b) Information on the methodologies employed to assess, measure, and monitor the environmental or social characteristics or the impact of the sustainable investments selected for the financial product, including its data sources, screening criteria for the underlying assets, and the relevant sustainability indicators used to measure the environmental or social characteristics or the overall sustainable impact of the financial product.

c) The information referred to in Articles 8 and 9 according 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.

d) The information referred to in Article 11 according 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.

Article 12 SFDR

The AIFM, according to the purpose of Article 12 of SFDR, aims and ensures that any information published in accordance with Article 3, 5, or 10 is kept up to date. Where an Investment Advisor or Delegated Portfolio Manager amend such information, a clear explanation of such amendment shall be published on the same website.