Sustainable Finance Disclosure Regulation ("SFDR")
The information below refers to our commitments under the European Union’s Sustainable Finance Disclosure Regulation (“SFDR”) ((EU) 2019/2088) which applies to Rathbone Luxembourg Funds SICAV. SFDR, which is part of a broader legislative package under the European Commission’s Sustainable Action Plan, came into effect on 10 March 2021. It seeks to harmonise ESG disclosures and set standards at both entity and product level.
The Investment Manager of Rathbone Luxembourg Funds SICAV (“the Company”), Rathbone Unit Trust Management Ltd (“RUTM”), prepares a summary to its sustainability-related information in relation to Articles 3(1), 4 5 and 10 of the SFDR. The information disclosed is required by law to help you understand the sustainability characteristics and/or objectives and risks of this financial product.
Rathbone Luxembourg Funds SICAV is governed by Luxembourg law. The Management Company is FundRock Management Company S.A., authorised in Luxembourg and regulated by the Commission de Surveillance du Secteur Financier (“CSSF”). The Luxembourg fund is authorised by the CSSF.
Consideration of sustainability risk in investment decision making - Article 3(1)
To meet the SFDR disclosure requirements, the Management Company identifies and analyses sustainability risk as part of its risk management process.
Sustainability risk means an environmental, social, or governance event or condition that, if it occurs, could potentially or actually cause a material negative impact on the value of a Sub-fund’s investment. Sustainability risks may have an impact on long-term risk adjusted returns for investors.
Rathbone Luxembourg Funds SICAV believes that the integration of this risk analysis could help to enhance long-term risk adjusted returns for investors, in accordance with the investment objectives and policies of the Sub-Funds. The Investment Manager therefore integrates sustainability risks in its investment process.
Adverse sustainability impacts - Article 4
The Management Company does not consider principal adverse impacts (“PAI”) of investment decisions on sustainability factors at entity level due to the nature of its activity and as it falls under the 500 employees’ threshold. The Management Company relies on investment management delegates to make investment decisions.
As at 1st January 2023, except for the Sub-Fund Rathbone SICAV Ethical Bond Fund, all other Sub-Funds do not consider PAI on sustainability factors as the investment policies of those Sub-Funds do not promote any environmental and/or social characteristics. The situation may, however, be reviewed going forward.
Transparency of remuneration policies in relation to the integration of sustainability risks - Article 5(1)
Rathbones Group’s (“Group”) commitment to be a leader in responsible business stems from our purpose in society – thinking, acting and investing responsibly.
From 2022, environmental, social and governance (ESG) measures will be incorporated into the variable pay component for our Group executive committee members, including our Group CEO and Group CFO. ESG measures include targets relating to progressing our near-term Net Zero targets and strengthening our community engagement.
Transparency on products which promote environmental or social characteristics or have sustainable investment as their objective - Article 10
The following fund has been classified as Article 8 products under the SFDR, which promote environmental or social characteristics:
RUTM does not run any SICAV sub-funds classified as Article 9 products under the SFDR.