SFDR Disclosure


Information required under the EU Sustainable Finance Disclosure Regulation (the “SFDR”)
Integration of sustainability risks


Threestones Capital Management S.A. Company’s policy on the integration of sustainability risks in its investment decision making process can be found on the website.


No consideration of sustainability adverse impacts
Threestones Capital Management S.A. Company ("TSC") is required to publish information on whether it considers the "adverse impacts of investment decisions on sustainability factors" (the "Principal Adverse Impacts") under the SFDR. TSC does not currently consider the Principal Adverse Impacts of investment decisions on sustainability factors as laid out in Article 4(1) of SFDR in connection with the products and services, as defined under and in accordance with the SFDR. This is because TSC is not, in its view, currently in a position to obtain and/or measure all the data which would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost with respect to all its investment strategies for investors.


TSC intends to consider and report to investors, applying the standards as in the SFDR, the Principal Adverse Impacts of investment decisions on sustainability factors in relation to those strategies where it has sufficient influence and control on the investment and provide that information to investors in the relevant funds.


In practice, depending on the investment strategy and product, Threestones Capital Management S.A. considers a relevant sub-set of the “sustainability factors” listed in the SFDR, including environmental, social and employee matters, respect for human rights, anti-corruption and/or anti-bribery matters by means of its global policy on integration of environmental, social and governance risks and value creation opportunities into its investment process. For further information, please contact TSC.
With respect to certain investment strategies and products, TSC has applied established ESG-related standards which vary depending on the investment strategy.


Date of publication: 10 March 2021.


Information on how remuneration policies are consistent with the integration of sustainability risks
TSC’s remuneration practices are designed to promote sound and effective risk management and not to encourage risk-taking which is inconsistent with its risk appetites or the risk profiles of the portfolios which TSC manages. TSC’s Responsible Investment Policy sets out how its investment process incorporates consideration of ESG risks. Such risks form part of the AIFM’s assessment of risk for the purposes of its remuneration policy. TSC’s approach to remuneration enables variable remuneration for employees to be adjusted for performance. This adjustment is not based solely on financial metrics. Qualitative non-financial performance metrics form a significant part of the assessment process. These metrics may include, for example, an employee’s failure to comply with applicable regulatory rules, unethical behaviour or other behaviour that is contrary to TSC’s Culture and Values. Consideration of these factors (including where relevant an individual’s contribution to ESG-related efforts) may form part of the employee’s performance assessment process.