Sustainable Finance Disclosure Statement (“SFDR”)

Responsible and Sustainable Investing

We do not assess Environmental, Social and Governance (“ESG”) Factors that may have investment ramifications, and which may have a material impact on the investment’s long-term financial performance. As a result, information on ESG Factors does not form part of our investment decision making process.

Negative and positive screening

We may, at our discretion, actively engage with our clients to understand whether they have concerns about specific activities and / or industries in order to exclude such investments on an on-going basis. In such cases, we undertake – to the extent possible – to screen target entities and /or products that promote and provide solutions that are consistent with ESG Factors and, shall aim at recommending / and or investing in such products on an on-going basis, in so far as possible.

Exclusions

We will not knowingly invest in entities involved in the following activities:

• arms manufacturing;
• manufacture of tobacco;
• hard spirits; and
• gambling.

We will assess these types of investments on a case-by-case basis and any potential for indirect exposure is carefully considered and factored into investment selection.

ESG Policy

The Company maintains a policy (the “ESG Policy”) which integrates sustainability risks and opportunities into its research, analysis and investment decision-making processes in respect of Environmental, Social and Governance issues (“ESG”), where applicable. The ESG Policy forms an integral part of its investment process and seeks to mitigate ESG and sustainability risks by ensuring that the Company only invests in companies or assets that are operated in an environmentally responsible manner, with respect for human rights and labour rights and providing good, healthy and safe working conditions and promote good governance conduct, always to the extent applicable and appropriate. Where applicable, consideration of potential ESG and sustainability risks related to a company or asset is integrated in the Company’s investment process, from transaction sourcing and selection to approvals and execution.

The consideration of sustainability risks and opportunities, when applied, may have a material impact on long-term returns for Shareholders. 

Potential risks are further identified in the due diligence process, by means of screening for ESG controversies or further ESG analysis as warranted in context of the specific investments and addressed for each investment on a case-by-case basis pursuant to the Company’s risk management framework and ESG Policy.

In respect of the Company and its Sub-Funds, with the exception of the AI Smart US Fund, the Investment Committee does not deem sustainability risks to be relevant to the Company and consequently does not make investments decisions in respect of the Company based on sustainability risks and does not consider the adverse impacts of sustainability factors on the returns it offers to its Shareholders as this does not fit in with any of the current investment strategies of the sub-funds of the Company.

Kindly contact info@levelecapital.com for a full copy of our ESG Policy.

Principle Adverse Impacts

We do not undertake an assessment of the Principal Adverse Impacts (“PAIs”) of our decisions on ESG Factors. PAIs are those impacts arising from a particular decision taken which we take that will eventually have a negative effect on ESG Factors.