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Rheingau Management GmbH
SFDR Website Disclosures
1. Policies on the Integration of Sustainability Risks (Article 3 SFDR)
A sustainability risk according to Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector ("SFDR") is 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.
Rheingau Management GmbH, manager of alternative investment funds (“AIFM”) considers sustainability risks in its investment decisions. As factors determining the performance of the investments, sustainability risks are part of the standard due diligence and risk assessment processes of the AIFM.
In particular, the following aspects are being considered: Sustainability risks such as a progressing climate change may lead to negative impacts on underlying assets. With respect to climate change, there are in particular actual physical risks (e.g. extreme weather events) and transition risks (e.g. costs for the transformation of the energy system). In the field of good governance and with regard to social characteristics, there are, for example, risks concerning the reputation of companies or potential claimed damages. Responding political and regulatory measures may also lead to considerable costs and the reduction of asset values.
The AIFM regularly reviews its due diligence processes to ensure that newly emerging risks are being considered.
2. No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors (Article 4 SFDR)
Currently, the AIFM does not consider any adverse impacts of its investment decisions on sustainability factors.
‘Principal adverse impacts’ according to the SFDR are the most significant negative impacts of investment decisions on sustainability factors relating to environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. ‘Sustainability factors’ mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.
Currently there is no established practice yet with regard to applying the provisions on principal adverse impacts. Also, due to the blind pool-character of the managed funds and the differences in investment strategies, the AIFM is not able to determine ex ante whether all of the portfolio companies of all of the managed funds will be providing sufficient data to properly consider all principal adverse impacts. Given the early-stage nature of the investment strategies of the managed funds, the availability of relevant (non-financial) information to assess the adverse sustainability impacts may be limited. As the managed funds will only be minority shareholders in portfolio companies, the AIFM is not in the position of power to ensure the adherence to standards or high-quality reporting on all necessary data for the assessment of principal adverse impacts on sustainability factors.
The AIFM will monitor developments with regard to available information and periodically reconsider whether it is reasonably possible to disclose the information required by the framework of Article 4 SFDR.
3. Remuneration Policies in Relation to the Integration of Sustainability Risks (Article 5 SFDR)
The AIFM, being registered within the meaning of Section 2 (4) of the KAGB, does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. Accordingly, the AIFM does not have a remuneration policy according to Article 5 (2) SFDR, in which to integrate the consideration of sustainability risks.