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At AlbaCore, we focus on the long-term. As one of Europe’s leading alternative credit specialists, we invest in private capital solutions, opportunistic and dislocated credit, and structured products. 

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Specialist in Asia Pacific, Japan, China, India and South East Asia and Global Emerging Market equities.

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Specialists in equity portfolios in Asia Pacific, emerging markets, global and sustainable investment strategies

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ESG/sustainability reporting (SFDR disclosures for Stewart Investors Article 9 Funds)

Sustainable Finance Disclosures Regulation

(Regulation (EU) 2019/2088)

The EU Sustainable Finance Action Plan, includes mandatory reporting and disclosure regulations in the form of the Sustainable Finance Disclosures Regulation (SFDR). The SFDR establishes a hierarchy of categories based on the products sustainability objective.

Compliance with the SFDR imposes mandatory sustainability disclosure obligations for asset management organisations promoting and distributing products and supplying portfolio management services within the EU. The regulation specifically applies to Stewart Investors funds within the First Sentier Investors Global Umbrella Fund plc.

Under Article 6 all investment products have to disclose the manner in which sustainability risks are integrated into investment decisions and the results of assessments of the likely impact of sustainability risks on the returns of the product. Products may also be classified as Article 8 (if they promote environmental or social characteristics) or Article 9 (if they have a sustainable investment objective). The Stewart Investors strategies are aligned to Article 9. 

Article designations for our strategies 

Article designation Summary features Investment strategy alignment
Article 6 All products must disclose the manner in which sustainability risks are integrated into their investment decisions.

All strategies

  • Asia Pacific and Japan Sustainability
  • Asia Pacific Leaders Sustainability
  • Asia Pacific Sustainability
  • European Sustainability
  • Global Emerging Markets Sustainability
  • Global Emerging Markets Leaders Sustainability*
  • Global Emerging Markets Ex-China Leaders Sustainability
  • Indian Subcontinent Sustainability
  • Worldwide Sustainability
  • Worldwide Leaders Sustainability
  • Pacific Assets Trust
Article 9 Any product which has a clear sustainability objective, incorporating both environmental and social aims, and that also meets various sustainability-related disclosure and reporting requirements.

* Also includes Global Emerging Markets Leaders products within this strategy.

What does Article 9 require us to do?

While Article 9 categorisation does not change our investment objective or our approach, it does require us to change the way we explain, illustrate and report the sustainable investment objective. We have been evolving our articulation over the last few years and examples of the steps we have taken include our work on Human Development PillarsProject Drawdown climate solutions and Portfolio Explorer which provides information on the investment rationale for every company we invest in, the contribution it makes to sustainable development, key risks and engagement topics.

Below is a summary of disclosures and explanations required for the official product documentation.

Sustainable investment objective

Sustainability indicators

No significant harm to the sustainable investment objectives

EU Taxonomy

Reporting

Below are links to the firm-level disclosures required to be made under SFDR by the First Sentier Investors group.

Article 3 – Policy relating to the integration of sustainability risks in our investment decision-making process.

Article 4 - Transparency of adverse sustainability impacts at entity level – Principal Adverse Impacts Statement.

Article 5 - Transparency of remuneration policies in relation to the integration of sustainability risks.

Article 10 - Transparency of the promotion of environmental or social characteristics and of sustainable investments on websites.

The Prospectus for the First Sentier Investors Global Umbrella Fund plc includes the latest SFDR appendix disclosing the required pre-contractual information for the Stewart Investors Article 9 funds such as environmental and social objectives (including any alignment to EU taxonomy), sustainability indicators, and principle adverse impacts.

The SFDR Level 2 reporting template for each of our Article 9 funds is available in a standalone document and also within the First Sentier Investors Global Umbrella Fund plc 2022 Annual Report.

References to ‘we’ in the content above means Stewart Investors, the Investment Manager of the Funds.

* Any reference to Project Drawdown is to describe the publicly available materials utilised by Stewart Investors in formulating its sustainability analysis. It is not intended to be, and should not be, read as constituting or implying that Project Drawdown has reviewed or otherwise endorsed the Stewart Investors sustainability assessment framework.

**A direct link would arise where the goods an entity produces or the services it provides are the primary means through which the positive social or environmental outcome can be achieved (e.g. solar panel manufacturers or installers).

An enabling link would arise if the goods a company produces or services it provides enable other companies to contribute towards the achievement of the positive social or environmental outcome (e.g. manufacturers of critical components that are used as inputs in the manufacture of solar panels).