SFDR DISCLOSURE
As a self-managed alternative investment fund, Frilsham is subject to Regulation (EU) 2019/2088, also known as the Sustainable Finance Disclosure Regulation or SFDR, which sets out requirements relating to sustainability‐related disclosures in the financial services sector, as applicable to ‘financial market participants’ such as Frilsham.
Following a sustainability risk assessment, Frilsham has determined that it does not restrict the investment objectives and policies to investments which require the integration of sustainability risks in Frilsham’s decision-making processes.
Frilsham believes that its responsibility is to endeavour to allocate capital responsibly in the shares of companies that It understands are seeking to operate within the law; it does not consider appropriate for fund managers to attempt to police the applicable laws. Notwithstanding, it remains Frilsham’s policy to perform an ongoing assessment of its products to ensure the suitability thereof for the identified target market.
The Frilsham Europe Equity Fund does not hold itself out to be a fund which actively promotes environmental or social investing in its investee companies, and does not take account of Principal Adverse Impacts in its investment process.
Statement on Principal Adverse Impacts
In accordance with Article 4(1)(b) of Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (“SFDR”), the Frilsham SICAV Plc (“the Fund”) hereby discloses that it does not currently consider the principal adverse impacts (PAIs) of investment decisions on sustainability factors.
Rationale for Non-Consideration
The decision not to consider PAIs has been taken based on the following factors:
1. Investment Strategy – The Fund’s strategy does not explicitly target environmental, social or governance (ESG) characteristics or pursue a sustainable investment objective.
2. Data Availability – There is material uncertainty regarding the availability, quality, veracity and consistency of data required to assess PAIs across the Fund’s investment universe.
3. Proportionality – The Fund is relatively small in scale and self-managed, with a single portfolio manager. Implementing the extensive systems and processes required for comprehensive PAI monitoring and reporting would therefore be disproportionate and would not result in meaningful benefits for investors at this stage.
Ongoing Review
The Fund will continue to monitor regulatory developments, industry practices, and data quality in this area. The decision not to consider PAIs may be revisited in the future should circumstances change, including the growth of the Fund or improvements in data availability.