No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors

BKN Capital is considered as a financial market participant within the meaning of the SFDR (“FMP”).  Where FMPs consider principal adverse impacts (“PAI”) of investment decisions on sustainability factors, SFDR Art. 4 requires to publish a statement on due diligence policies with respect to those impacts, taking due account of their size, the nature and scale of their activities and the types of financial products they make available. This statement has been developed taking into consideration SFDR Art. 7 on the transparency of PAI at product level.

 

Where BKN Capital acts itself as PM, for the time being, BKN Capital does not consider adverse impacts of investment decisions on sustainability factors in line with SFDR Art. 4(1)(point b). The main reason for not considering adverse impacts of investment decisions on sustainability factors at the company level is the lack of further information and relevant data of the required quality to identify, adequately assess and weight sustainability-related PAI.

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BKN Capital will continue reviewing the situation on a regular basis and may decide on this basis on the possibility of taking into account PAI of investment decisions on sustainability factors in the future.

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Where BKN Capital delegates portfolio management, the PM may already consider PAI on its investment decision for the Funds they manage. Should such PM wish to consider PAI in line with SFDR Art. 7 in respect of the Fund it manages, BKN Capital ensures that:

1. The PM has the appropriate infrastructure in place to report on PAI on an ongoing basis;

2. The appropriate disclosures are made in the pre-contractual documents;

3. A report on the PAI considered is available on request and will contain sufficient and appropriate information as to the assessment of PAI; and

4. The PM also provides or publishes appropriate disclosures.

 

The processes, systems and procedures in place to consider and report on PAI in respect of each Fund remain subject to BKN Capital’s periodic due diligence.

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Please note that in the case where BKN Capital cooperates with PMs not located in one of the Member States of the EU, further information with respect to the PAI of their investment decisions on ESG factors might not be available.

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For recent developments or any further queries relating to BKN Capital’s sustainability-related disclosures, please contact: Compliance@bkncapital.lu.

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