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PAI Statement

As permitted under Article 4 of Regulation (EU) 2019/2088 (the “SFDR”), Harrington Cooper Asset Management Limited (‘HCAML’) does not consider adverse impacts of investment decisions on sustainability factors on the basis that it is not a financial market participant that is required to do so given that HCAML does not have on its balance sheet an average number of employees exceeding 500 during the financial year. HCAML may choose at a later date to publish and maintain on its website the consideration of principal adverse impacts of investment decisions on sustainability factors. HCAML will review its approach to considering the principal adverse impacts of investment decisions on sustainability factors within the meaning of SFDR on a periodic basis.

However, as Funds, for which HCAML act as Manager, follow a number of different investment strategies with varying consideration of environmental, social and governance (ESG) and sustainability factors, PAI can be considered on case by case at the level of Funds.

Should Investment Managers wish to consider PAI in respect of the Funds in line with Article 7 of SFDR, HCAML shall ensure that:

  • The delegated Investment Manager has the appropriate infrastructure in place to report on PAI on an ongoing basis;
  • Where PAI are to be considered in respect of the Funds, the appropriate disclosures are made in the pre-contractual documents in line with SFDR by 31 December 2022;
  • The list of Funds for which PAI are considered is available on request;
  • The processes, systems and procedures in place to consider and report on PAI in respect of each Fund shall remain subject to HCAML’s periodic due diligence;
  • The Investment Manager also provides or publishes on its website appropriate disclosures in accordance with Article 4(1) and (2) of SFDR, while also considering the associated regulatory technical standards once adopted by the European Commission, in respect of the Funds;
  • The periodic reports of the Funds contain sufficient and appropriate information in relation to the assessment of PAI;
  • Where PAI are not considered in respect of the Funds to which HCAML act as Manager, HCAML shall ensure appropriate disclosures are contained within the relevant pre-contractual documents. For further information as to why PAI are not considered in respect of a particular Fund, please refer to the prospectus/supplement of that Fund.
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