ESG Disclosures in accordance with SFDR
Last revised on June 28th, 2023Maxus, in its capacity of alternative investment fund manager ('AIFM'), is subject to the disclosure obligations relating to environmental, social and governance ("ESG") matters as set forth in:
- Regulation (EU) no. 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector ("SFDR");
- Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying the details of the content and presentation of the information in relation to the principle of 'do no significant harm', specifying the content, methodologies and presentation of information in relation to sustainability indicators and adverse sustainability impacts, and the content and presentation of the information in relation to the promotion of environmental or social characteristics and sustainable investment objectives in precontractual documents, on websites and in periodic reports ("RTS"); and
- Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 ("TR").
Maxus reserves the right to modify this information at any time, and will in such event publish a clarification on such amendment on this website.
1. No integration of sustainability risks
Maxus acknowledges that ESG-related events or conditions could potentially impact the value of the investments managed by the company. At this time however, due to limited size and resources, we do not formally integrate sustainability risks into our investment decision-making process, as outlined in Article 3 of the SFDR.
Despite that, we strive to make informed investment decisions taking into consideration relevant ESG factors. We remain committed to monitoring and evaluating the evolving landscape of ESG-related matters to ensure responsible investment practices.
2. No consideration of adverse sustainability impacts of investment decisions
At Maxus, we are fully aware of the potential impact our investment decisions and the activities of our portfolio entities might have on sustainability factors. However, for the purposes of Article 4 of the SFDR, we do not currently consider the adverse impacts of our investment decisions on sustainability factors.
We want to provide full transparency regarding the reasons behind this decision. As a small organization with limited resources and personnel, we face significant challenges in precisely determining the adverse impacts of our investment decisions based on the various criteria outlined in the SFDR and its implementing legislation.
We understand the importance of sustainability and the need to address adverse impacts. While we are currently unable to meet the requirements set forth in the SFDR, we remain committed to exploring opportunities to enhance our sustainability practices within the scope of our resources and capabilities.
3. Integration of sustainability risks into remuneration policies
As a sub-threshold manager of alternative investment funds, Maxus does not have an obligation to have a formal remuneration policy in accordance with article 40 and following of the Belgian law of 19 April 2014 on alternative entities for collective investments and their managers. Consequently, sustainability risks are not integrated in the remuneration policy.