Sustainability Disclosure
The European Commission’s Sustainable Action Plan has three main objectives:
Reorient capital flows towards sustainable investment to achieve sustainable and inclusive growth.
Manage financial risks stemming from climate change, environmental degradation, and social issues.
Foster transparency and long-termism in financial and economic activity.
This initiative follows recommendations from the high-level expert group on sustainable finance, which were submitted to the European Commission in January 2018.
Regulatory Development
The European Parliament has already adopted several amendments to integrate Environmental, Social, and Governance (ESG) considerations into financial regulations, including:
Regulation 2016/1011: Introducing a framework for EU climate transition and EU Paris-aligned benchmarks.
Delegated Regulation 2017/565: Incorporating ESG considerations into investment advice and portfolio management.
Delegated Regulation (EU) 2017/2359: Integrating ESG factors into investment advice for insurance-based investment products.
Related reports, such as EU Taxonomy Regulation, EU Green Bond Standard, and Climate-Related Disclosures.
Sustainable Finance Disclosure Regulation (SFDR)
The SFDR, a key component of the European Commission’s Sustainable Action Plan, came into effect on 10 March 2021.
To comply with SFDR disclosure requirements, NEVERWINTER MANAGEMENT Sàrl:
Identifies, assesses, and seeks to manage sustainability risks as part of its risk management process.
Believes that integrating sustainability risk analysis could enhance long-term portfolio value for investors.
However, due to the investment objective’s nature, sustainability risks are not integrated into investment decisions.
Investment Classification Under SFDR
The Partnership does not promote environmental or social characteristics under Article 8 of SFDR.
It does not have a sustainable investment objective under Article 9 of SFDR.
As per Article 6 of the EU Taxonomy Regulation, NEVERWINTER MANAGEMENT Sàrl confirms that the investments underlying this financial product do not take into account EU criteria for environmentally sustainable economic activities.
Under Article 4(1) of SFDR, it is confirmed that NEVERWINTER MANAGEMENT Sàrl does not take into account negative impacts due to investments (Article 4(1)(b)).
