Statement pertaining the non consideration of Principle Adverse Impacts

Legal framework

Intervest Capital Partners S.à r.l. is an alternative investment fund manager authorized by the CSSF in Luxembourg under chapter 2 of the AIFM Law (as defined below) and Article 125-2 of the Luxembourg law of 17 December 2010 on undertakings for collective investment. Within the scope of its regulatory authorisation, the AIFM manages funds that qualify as undertakings for collective investments (“UCIs”) under the Chapter 16 of the Law of 17 December 2010 and alternative investment funds (“AIF”) (hereinafter “investment funds”), under the Law of 12 July 2013.

Sustainability-related disclosures in the financial services sector

On 27 November 2019, Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosure requirements in the financial services sector (hereinafter “SFDR”) was published and entered into force on 10 March 2021. The main objective of the SFDR is to create transparency on:

how sustainability risks are considered in the management of investment funds; and
if principal adverse impacts of investment decisions on sustainability factors (“comply or explain”) are considered in the management of investment funds.

These transparency requirements apply in principle to both the AIFM and the managed investment funds.

In addition, on 18 June 2020, Regulation (EU) 2020/852 was adopted by the European Parliament and Council with regards to the establishment of a framework to facilitate sustainable investment, amending therefore the Regulation (EU) 2019/2088 mentioned above. The objective of this regulation is to establish the general framework for determining the degree to which an investment is environmentally sustainable.

Completing the European ESG regulatory framework, the Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing the Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (hereinafter the “Level 2 SFDR”) was published on 25 July 2022. As a result, the main purpose of the Level 2 SFDR is to disclose sustainability related information in pre-contractual documents (i.e. prospectus for the investment funds), on website and in periodic reports (i.e. the annual reports for the investment funds). The type of disclosure depends mainly on whether the financial products follow the regime of Article 8 or Article 9 of SFDR, while provisions related to PAIs-related disclosures will also apply to the so-called article 6 products.

Purpose of this document- explain statement

This policy describes the AIFM’s decision with respect to the requirements of article 4 (1) SFDR regarding the consideration of principal adverse impacts (hereinafter “PAIs”) of investment decisions on sustainability factors.

For the time being, Intervest Capital Partners has taken the decision to not take into consideration PAIs of investment decisions on sustainability factors.

The main reasons for choosing not to take into consideration PAIs in the course of the investment decision making process are the following:

Data Availability and Quality: At present, there is a lack of reliable, consistent, and comprehensive data on the Principal Adverse Impacts of investments. The availability of relevant data is insufficient to enable a robust and accurate assessment of PAIs across our entire investment portfolio. Without high-quality data, any PAI assessment would risk being incomplete, potentially leading to misleading conclusions.
Investment Focus: Our investment approach prioritizes financial returns and long-term value creation for our clients, with sustainability factors considered to the extent that they affect the risk and return profile of a fund. However, currently the AIFM exclusively manages non-sustainable products, i.e. products without any commitment towards a consideration of environmental- and / or social characteristics or towards the pursue of a sustainable investment objective. As a consequence, no products are managed by the AIFM which are subject to SFDR article 8 or 9.

Review of positioning

From time to time, the AIFM will review its positioning regarding the non-consideration of PAIs in the context of investment decisions. The decision to change its positioning shall be influenced by factors such as an increased non-financial data availability for the underlying assets of our funds or a change in the sustainability commitments made towards the investor, i.e. the management of funds subject to SFDR article 8 and / or SFDR article 9.

Principal adverse impacts – Regulatory framework & context

Principal adverse impacts – Context of the SFDR

PAIs are to be understood as those impacts of investment decisions that result in negative effects on sustainability factors (recital 20 of the SFDR). The SFDR is requiring both, the AIFM as well as the managed investment funds, in article 4 (1) respectively 7 of the SFDR to state if PAIs are being considered.

SFDR Level 2 is detailing further requirements at the level of the AIFM in case PAIs are considered for the managed funds in Articles 4 – 10 of SFDR Level 2. Since the AIFM does not consider PAIs for the managed funds, these Articles are not applicable for the time being.

Principal adverse impacts – Link with sustainability factors and sustainability indicators

According to article 2 (24) SFDR sustainability factors mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. For each sustainability factor different underlying sustainability indicators can in principle be identified (e.g. carbon footprint, wage equality, compliance with the requirements of the General Data Protection Regulation, Regulation (EU) 2016/679).

SFDR Level 2 is defining sustainability indicators that are considered as principal adverse impacts in Annex I, Tables 1-3, of SFDR Level 2. A differentiation is made for the PAI indicators that are relevant to:

investee companies;
sovereigns and supranationals; and
real estate assets.

Principal adverse impacts – Link with sustainability risk

The SFDR is establishing a link between the requirement to consider sustainability risks in the investment decision-making process (article 3 SFDR) and the consideration of principal adverse impacts of investment decisions on sustainability factors (article 4 SFDR). Both concepts share the same core foundation, i.e. they commence with the identification and consideration of relevant sustainability indicators.

In general, the identification and consideration of relevant sustainability indicators are inter alia dependent on the investment strategy as well as the geographical and sectoral focus of the managed investment funds. The monitoring of relevant sustainability indicators allows to establish a better and more informed understanding regarding the identification of (potential) sustainability risks. Further the assessment of certain sustainability indicators may be prioritised within the investment decision-making process to eliminate or at least mitigate sustainability risks.

Article 2 (22) of the SFDR defines sustainability risk as 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.

Principal adverse impacts – Requirements of the SFDR relevant for this statement

As of 10 March 2021 the SFDR imposes certain transparency requirements to AIFMs concerning their positioning regarding the consideration of PAIs in the context of investment decisions. Depending on the positioning of the AIFM as per SFDR article 4(1), a different level of disclosures is required.

Summary of requirements

Art. 4 (1) (b)

Financial market participants shall publish and maintain on their websites, where they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons for why they do not do so, including, where relevant, information as to whether and when they intend to consider such adverse impacts.

Level: AIFM

Implementation: Description in this statement

Last review of this statement: September 2025