Sustainability-related disclosures

This section of the website sets out the entity-level disclosures by Claret Capital Partners Limited (“Claret“) under Articles 3, 4 and 5 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR“).

This disclosure applies to Claret in respect of funds (i) in relation to which Claret acts as delegated portfolio manager or third country alternative investment fund manager and (ii) that fall within the scope of the SFDR (“In-scope Funds“) as a result of such In-scope Funds being marketed into the European Union.

I. Sustainability risks

Article 3, SFDR

Pursuant to the SFDR, ‘sustainability risk’ means 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.

Claret considers sustainability risks as part of its investment decision-making process. In particular, Claret considers sustainability risks as part of its due diligence process prior to any investment. Through the application of negative screens, due diligence (including ESG) questionnaires and/or documentation of ESG risks and opportunities in Investment Committee Memos, sustainability risks are considered throughout the deal origination, due diligence and investment decision processes. However, Claret remains free in its decision to refrain from investing or to invest, despite sustainability risks, in which case Claret can also apply measures to reduce or mitigate any sustainability risks. At all times, Claret will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.

II. No consideration of adverse impacts of investment decisions on sustainability factors

Article 4, SFDR

Claret does not consider any adverse impacts of its investment decisions on sustainability factors within the meaning of the SFDR.

Claret will continue to consider its position in relation to consideration of adverse impacts and will review its approach on an annual basis.

III. Remuneration disclosures

Article 5, SFDR

Claret maintains a remuneration policy. The remuneration policy seeks to ensure that Claret’s remuneration practices appropriately align the incentives of its employees and managers with the risk profiles (including in relation to sustainability risks) of the funds that Claret sponsors.

IV. Product-specific information

Article 10, SFDR

Product-specific disclosures pursuant to Article 10 of the SFDR can be found in the data room.

SFDR Website Disclosures first published: 2025-03-27