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Disclosures related to sustainability (SFDR)

FIMED Sàrl takes into account potential sustainability risks and/or opportunities in its analysis of investment opportunities and in the investment decision-making process in accordance with the provisions established in Regulation (EU) No. 2019/2088 of the European Parliament and of the Council of 27 November 2019 (as amended) on the disclosure of information related to sustainability in the financial sector (SFDR).


Portfolios are managed by integrating environmental, social and governance (ESG) risks and factors on a case-by-case basis and depending on the characteristics of each proposed individual portfolio investment, including products that do not promote ESG characteristics or have specific sustainable characteristics. investment objectives. This means that while ESG factors are considered, they may or may not impact portfolio construction. The impact of ESG integration on investment performance may change over time.


The individual sustainability/ESG risk factors considered for each specific investment depend on the investment strategy of each managed AIF, as well as the economic sector and geographic exposure of the target investment, and may include, in particular:


  • Environmental: Material negative impacts of investment decisions related to the quality and functioning of the natural environment and natural systems, including greenhouse gas emissions, non-renewable energy use, biodiversity, water and waste;

  • Social: Negative material adverse impacts of investment decisions related to the rights, well-being and interests of people and communities; and

  • Governance: Material negative adverse impacts arising from corporate governance issues, including inadequate management of conflicts of interest, violation of anti-money laundering regulations, etc.


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


Adverse impacts of investment decisions on sustainability factors are not taken into account.

Currently, FIMED Sàrl does not consider or disclose adverse impacts on sustainability in accordance with point (a) of Article 4(1) of the SFDR in the category of “Financial Market Participant”. This is due to the absence of (i) sufficient data/information, and (ii) sufficient quality of such data/information for the assessment of potential adverse impacts on sustainability at the time of investment and on an ongoing basis. Furthermore, FIMED Sàrl manages products with a wide variety of investment strategies and underlying assets, both in type of assets and size of investments. Therefore, the significance of the data and the evaluation of its evolution seem significantly impaired.


However, key policies and adverse impact statements for certain products or subsets of products may be posted below in the future where relevant.

Disclosure on the integration of sustainability risks in the remuneration policies of FIMED Sàrl.


The Remuneration Policy of FIMED Sàrl integrates aspects related to sustainability; In particular:


The criteria for periodically determining individual and collective variable remuneration incentives will take due account of present and future risk factors related to sustainability;

The remuneration policies of the delegated portfolio manager shall include appropriate and equivalent provisions in relation to the integration of sustainability risks.

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