SFDR Disclosures

This disclosure ensures compliance with the Sustainable Finance Disclosure Regulation (SFDR 2019/2088 and 2022/1288). As these regulations have not yet been fully consolidated, the first part of this disclosure addresses SFDR 2019/2088 and the second part SFDR 2022/1288.

SFDR Statement (2019/2088)

The following disclosure relates to Interface Capital Management GmbH (LEI: 529900QT0ZA4VHUAE241):

This statement includes three sections:
  • Transparency of sustainability risk policies (2019/2088 – 3-1)
  • Transparency of adverse sustainability impacts (2019/2088 – 4-1-b)
  • Transparency of remuneration policies in relation to the integration of sustainability risks (2019/2088 – 5)

Transparency of Sustainability Risk Policies

Interface Capital Management GmbH addresses sustainability risks in its investment decision-making process insofar as relevant. ‘Sustainability risk’ means 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 the investment. When identifying a sustainability risk during the due diligence on potential investments, Interface Capital Management GmbH decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk. Interface Capital Management GmbH regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns. The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Transparency of Adverse Sustainability Impacts

Interface Capital Management GmbH does not consider principal adverse impacts of investment decisions on sustainability factors. ‘Sustainability factors’ mean environmental, social and employee matters, respect for human rights, anti‐ corruption and anti‐bribery matters. Interface Capital Management GmbH does not use sustainability indicators.

Considering the numerous legal uncertainties currently related to the application of the provisions of the Sustainable Finance Disclosure Regulation (EU 2019/2088) (EU 2022/1288) and the Regulatory Technical Standards (“RTS”) – in particular with respect to the consideration of adverse impacts – and the administrative burden resulting from such uncertainties, Interface Capital Management GmbH is not in a position to commit to such standard in light of its fiduciary duty to the fund and its investors. Interface Capital Management GmbH will constantly monitor and review the evolution around such regulations and standards and considers changing its position on adverse impacts once (i) a best practice has evolved among market participants, (ii) there is clear guidance by the administrations on the application of such regulations and (iii) the consequences of a commitment towards the consideration of principal adverse impacts are reasonably clear to Interface Capital Management GmbH.

Transparency of Remuneration Policies in Relation to the Integration of Sustainability Risks

As a registered alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB), Interface Capital Management GmbH does not have and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.

SFDR Statement (2022/1288)

The following disclosure relates to Interface Capital Management GmbH (LEI: 529900QT0ZA4VHUAE241):

Statement of Principal Adverse Impacts on Investment Decisions on Sustainability Factors

Kindly refer above to the headline ‘Transparency of Adverse Sustainability Impacts’ for the PAI Statement. The present statement on PAI on sustainability factors covers the reference period from 1 January 2023 to 31 December 2023.

Date of Publication:

This document was last updated on 20/05/2024 to incorporate amendments and additions from the 2022/1288 SFDR update. If you have any questions, please do not hesitate to contact us at esg@ace-alternatives.com.

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