The Sustainable Finance Disclosure Regulation (”SFDR” or “the Regulation”) applied from 10 March 2021. This Principal Adverse Sustainability Impacts Statement specifically addresses the obligation in Articles 4(1)(b) and 4(5)(b) of the Regulation which requires financial market participants and financial advisers respectively to publish and maintain on their websites:
“[in the case of financial market participants] where they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons for why they do not, including, where relevant, information as to whether and when they intend to consider such adverse impacts…[and, in the case of financial advisers]…information as to why they do not to consider adverse impacts of investment decisions on sustainability factors in their investment advice or insurance advice, and, where relevant, including information as to whether and when they intend to consider such adverse impacts”
“Sustainability Factors” are defined in Article 2(24) of the Regulation as: “environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters”.
No consideration of adverse impacts of investment decisions on sustainability factors
Isomer Capital LLP does not consider the adverse impacts of its investment recommendations on sustainability factors.
Given the obligations contained in the Regulations (including the technical methodologies and data capture requirements this would reasonably entail) compliance is not assured among the different portfolio funds and companies that Isomer Capital LLP’s client fundswill invest in. As such, there is no assurance that Isomer Capital LLP will have access to clear, comparable and consistent data with which to report on principal adverse impacts of investment decisions on Sustainability Factors. This decision will, however, be kept under regular review.