EU Sustainable Finance Disclosure Regulation

Information required under the EU Sustainable Finance Disclosure Regulation (the “SFDR”)

Atwater Capital L.P intends to consider and report to investors, on a voluntary basis, applying the same standards as in the SFDR, the Principal Adverse Impacts of investment decisions on sustainability factors in relation to those strategies where it has sufficient influence and control on the investment and provide that information to investors in the relevant funds.

In practice, depending on the investment strategy and product, Atwater Capital L.P considers a relevant sub-set of the “sustainability factors” listed in the SFDR, including environmental, social and employee matters, respect for human rights, anti-corruption and/or anti-bribery matters by means of its global policy on integration of environmental, social and governance risks and value creation opportunities into its investment process. For further information, please email webmaster@atwater-capital.com

With respect to certain investment strategies and products, Atwater Capital L.P has applied established ESG-related standards which vary depending on the investment strategy. Atwater Capital L.P is a signatory to the United Nations-backed Principles for Responsible Investment (PRI).

Information on how remuneration policies are consistent with the integration of sustainability risks

Atwater Capital L.P and Atwater Capital L.P CAI’s remuneration practices are designed to promote sound and effective risk management and not to encourage risk-taking which is inconsistent with their risk appetites or the risk profiles of the portfolios which they manage. Atwater Capital L.P’s Responsible Investment Policy sets out how its investment process incorporates consideration of ESG risks. Such risks form part of Atwater Capital L.P  and Atwater Capital L.P CAI’s s assessment of risk for the purposes of its remuneration policy. 

Atwater Capital L.P  and Atwater Capital L.P CAI’s approach to remuneration enables variable remuneration for employees to be adjusted for performance. This adjustment is not based solely on financial metrics. Qualitative non-financial performance metrics form a significant part of the assessment process. These metrics may include, for example, an employee’s failure to adhere to effective risk-management, to comply with applicable regulatory rules, unethical behaviour or other behaviour that is contrary to Atwater Capital L.P’s Culture and Values. Consideration of these factors (including where relevant an individual’s contribution to ESG-related efforts) may form part of the employee’s performance assessment process. In addition, a proportion of the variable remuneration for employees may be deferred. This allows ex-post performance adjustments to be applied to deferred remuneration where risks, including sustainability risks, materialise in the future.