Sustainability Risk Policy – SFDR Disclosure Statement

Chorus Capital Management Limited (“Chorus Capital” or the “Firm”)

In accordance with the requirements of Article 3 of Regulation (EU) 2019/2088 on sustainability‐related disclosures (the “Disclosures”) in the financial services sector (“SFDR” or the “ESG Disclosure Regulation” where ESG stands for Environment, Social, and Governance) Chorus Capital has chosen to make the limited disclosures below. 

The funds managed by the Firm do not directly target ESG objectives though they are subject to a number of constraints as detailed in Chorus Capital’s Responsible Investment Policy ("RI"). The latter, as well as the Firm’s ESG Policy are available to existing and prospective Limited Partners upon request. The nature of the Firm’s investment strategy whereby no direct position is taken in a company’s capital structure means not all suggested metrics under SFDR can be reflected in its RI policy for the time being. 

Further, the Firm is not in a position to consider Principal Adverse Impacts (“PAIs”) as defined under Article 4 SFDR. It is making this disclosure to explain why that is: given the Firm’s size and the nature of the investment strategy pursued by the funds it manages, it is neither deemed proportionate nor practicable to collect relevant data to comply with the PAI-related requirements. As the market matures and additional data points are made available, be they from originating banks the Firm sources investment opportunities from, and/or market data providers, the opportunity to make additional disclosures will be considered.

REMUNERATION POLICY

This section pertains to the integration of sustainability risk into the Firm’s remuneration policy (the “Policy”), in line with Regulation (EU) 2019/2088. The Firm, as a full scope AIFM approved and regulated by the UK Financial Conduct Authority, has a stand-alone Policy that further describes and governs remuneration arrangements made for in-scope employees.

ESG considerations form an integral part of Chorus Capital’s investment process and subsequent monitoring of transactions. As a factor that contributes to the performance of the funds the Firm manages (or might detract from it), it feeds into the remuneration of its employees by way of performance appraisals. Compliance with policies and procedures (inc. those relating to the impact of sustainability risks during the investment decision-making process) is thereby formally assessed and may negatively impact remuneration awards should one’s behavior be determined to be lacking.

These Disclosures are made for information purposes only. Should there be any discrepancy between these Disclosures and either (i) the Policy, or (ii) the terms of any agreement between the Firm and any of its clients, now or in the future, such other document(s) shall prevail. No liability is accepted by the Firm in respect of the Disclosures (to the maximum extent permitted by law).



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