ESG

Article 3 - Integration of sustainability risks

We integrate sustainability risks into our overall risk management framework, in line with the SFDR and applicable CSSF requirements. Sustainability risks are environmental, social or governance events or conditions that could materially affect the value of an investment: environmental risks such as climate change, resource scarcity and biodiversity loss; social risks such as human rights violations, labour issues and community impacts; and governance risks such as corruption, weak shareholder rights and a lack of transparency.

Sustainability risks are assessed alongside other material risks, including market, credit, liquidity, counterparty, operational, business, regulatory and ICT risk. They are embedded in investment due diligence and in ongoing monitoring across all asset classes we manage.

Risk assessments are reviewed regularly by the Risk Manager and presented quarterly to the Management Board. The Board defines, approves and oversees the sustainability strategy; the ESG Sustainability Committee advises on integration, reviews sustainable products, oversees due diligence and reporting, and works with compliance, risk management and internal audit.

Article 4 - Principal adverse impacts

We do not currently consider the principal adverse impacts of our investment decisions on sustainability factors at entity level within the meaning of Article 4 SFDR. The reason is the absence of sufficient data and information, and of sufficient quality of such data, to provide a meaningful and consistent assessment across all managed assets. We keep this position under review and will reconsider it as data availability and quality develop.

Individual funds may nonetheless consider principal adverse impacts as part of their own sustainability strategy. Where this is the case, the approach is described in that fund’s Article 10 disclosure and in the fund documentation provided to investors.

Article 5 - Remuneration policy

Our remuneration policy is consistent with the integration of sustainability risks. Incentives are aligned with responsible long-term performance rather than short-term results, so that remuneration does not encourage risk-taking that is inconsistent with the sustainability risk profile of the funds under management. Information on the remuneration policy is available to investors on request.