The Sustainable Finance Disclosure Regulation (”SFDR” or “the Regulation”) applied from 10 March 2021. This Sustainability Risk Policy specifically addresses the obligation in Article 3 of the Regulation which requires either financial market participants and/or financial advisers (as applicable) to:
“…publish on their websites information about their policies on the integration of sustainability risks in their [in the case of financial market participants] investment decision‐making process or [in the case of financial advisers] investment advice or insurance advice [(as applicable)].”
“Sustainability Risks” as defined in Article 2(22) of the Regulation: “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment”.
Sustainability Risks include (but are not limited to) the following:
- environmental risks such as the impact of environmental events such as increased flooding risks on operations of portfolio companies;
- social risks such as impact of non-compliance with anti-slavery or working conditions laws and regulations by portfolio companies; and
- governance risks such as inadequate management oversight of portfolio companies.
Integration of sustainability risks in investment processes
Isomer Capital LLP is a signatory to the United Nations Principles for Responsible Investing (UNPRI) and includes environmental, social and governance issues (ESG) in decision-making, investing, and monitoring processes where appropriate. ESG related factors are one of many factors that the firm considers when evaluating an investment decision. In addition, the firm incorporates ESG-related questions in its due diligence on portfolio funds and companies.
Isomer Capital LLP has an ESG policy (available upon request), which covers Sustainability Risks. This policy is reviewed regularly and amended as required.