Sustainability-related disclosures
Strategy for integrating sustainability risks
Golding Capital Partners (Luxembourg) S.A. as a financial market participant (AIFM) and Golding Capital Partners GmbH as a financial adviser within the meaning of the SFDR (hereafter known collectively as “Golding” or “we”) considers ESG factors in the course of its investment and investment advisory process, because they may have material negative impacts on the value of investments (‘sustainability risks’).
As financial market participants (AIFM) and financial adviser our investment and investment advisory process considers environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment (known as “sustainability risks”). Furthermore, we consider the impacts of any sustainability risks on the assets, financial position, earnings and reputation of Golding and of the funds that we manage and advise. A multi-stage management approach is used for this purpose.
We are aware that our influence over our investments depends on the way in which the investment has been made. With co-investments there is greater scope for exerting an influence than with fund investments, where a primary fund manager is also involved in the process between the funds managed and advised by us and the individual company or project.
When we act as fund-of-fund manager we can generally not guarantee that all the relevant information about the sustainability risks to a target fund’s specific portfolio companies or projects are already available at the time we make our investment decision or provide our advice.
Our approach depends on how the investment is sourced
With fund investments we primarily assess the ESG approach of the target fund manager in the due diligence phase of our investment and investment advisory process. We evaluate the extent to which the target fund manager is committed to responsible investing and has integrated sustainability risks and other ESG aspects into its investment decision-making process and consider this evaluation in our own investment decision or advice. An analysis of how the respective target fund addresses sustainability risks, by reference to the SFDR classification of the fund, for example, and the relevant disclosures by the target fund are additional elements that are considered in the investment decision or advice. Over the lifetime of the investment (during the monitoring phase) we work to obtain information from the target fund managers about their own ESG performance and that of their individual portfolio companies or projects. On this basis we identify potential for improvements and discuss these with the target fund manager with the aim of integrating sustainability risks appropriately into the respective target fund and thereby indirectly into our investments also. In addition, we periodically review the target fund manager’s ESG approach, also in order to judge how the integration of sustainability risks by the target fund manager has evolved.
For co-investments, whenever possible we assess the lead investor’s ESG approach in the due diligence phase using the same metrics as we apply to a target fund manager. In addition, we evaluate available information about the ESG performance of the portfolio companies or projects and include these in our investment decision or advice. Over the lifetime of the investment, and to the extent that it results from our initial analysis or arises during the continuous monitoring phase, we endeavour to work with the lead investor to identify improvement potential for the ESG performance of the portfolio company or project.
ESG aspects can be a knock-out criterion
For all investments, however sourced, we reserve the right to reject an investment if information about the adequate assessment and integration of sustainability risks is not available for the respective investment process or the information is insufficient or the ESG performance does not conform to our principles. We have established a minimum standard for investments in terms of conduct and commercial activities, compliance with which is required under our Responsible Investment Policy.
Selected funds currently promote ESG characteristics
The following funds managed by us currently promote environmental and/or social characteristics within the meaning of Article 8 SFDR:
- Golding Infrastructure 2022 SCS SICAV-FIAR Subfund A and Subfund B
- Golding Infrastructure 2022 Feeder FCP-FIAR Subfund A and Subfund B
- Golding Infrastructure Co-Investment 2023 SCS SICAV-FIAR
- Golding Infrastructure Co-Investment 2020 SCS SICAV-FIAR
- Golding Infrastructure Co-Investment 2020 Parallel SCS SICAV-FIAR
- Golding Buyout Co-Investment 2023 SCS SICAV-FIAR
- Golding Private Debt Co-Investment 2021 SCS SICAV-FIAR
- Golding Buyout 2021 SCS SICAV-FIAR
- Golding Secondaries 2022 SCS SICAV-FIAR
In addition, the following funds managed by us have sustainable investment as their objective within the meaning of Article 9 SFDR:
- Golding Impact 2021 SCS SICAV-FIAR
- Golding Impact 2021 Feeder FCP-FIAR
Further transparency disclosures on these funds pursuant to Article 10 SFDR and Art. 24-36 and Art. 37-49 of the Commission Delegated Regulation (EU) 2022/1288 (SFDR Level 2) can be found here.
Information about how the principal adverse impacts of investment decisions on sustainability factors are considered at the level of the entity
Golding Capital Partners (Luxembourg) S.A. as portfolio manager (AIFM) and Golding Capital Partners GmbH as financial (investment) adviser in terms of the European Sustainable Finance Disclosure Regulation (SFDR) (together in the following »Golding« or »we«) take ESG factors into account in our investment and investment advisory process, as these may have substantial negative effects on the value of an investment (›sustainability risks‹).
Sustainability factors are considered as far as is possible
We consider the impact of our investment decisions on ESG concerns alongside human rights and the fight against corruption and bribery (the principle adverse impacts or PAI) in our investment/investment advisory process.
We are also aware that the amount of information available to us before making an investment decision/recommendation significantly depends on the investment type. Whereas with co-investments the most important adverse impacts on sustainability and sustainability factors can generally be determined early on, with fund investments the specific portfolio companies and projects of a target fund are in many cases not yet known at the time of our investment decision/recommendation.
If we do not have such information, we cannot assume that we properly consider the most important adverse impacts on sustainability of our investment decisions/recommendations on sustainability factors.
Attainment of information in the due diligence phase
Independent of the investment type, we gather information by appropriate means in the due diligence phase. When acting as a fund-of-funds manager or advising on such a fund, we also assess the approach of the target fund manager and evaluate how it prioritises and identifies the essential adverse impacts.
Adverse impacts on sustainability can be very diverse
The adverse impacts on sustainability can, depending on the asset class of our investments as well as the industries and sectors of the portfolio companies and projects, be very diverse. The same naturally applies to the measures we take in individual cases.
We adhere to a code of responsible corporate governance
In the interest of responsible corporate governance, we have therefore established and refined the »rules of conduct« for financial service providers in the guidelines and processes of our organisation handbook »Code of Conduct«.
Principal Adverse Impact consideration at entity level
The number of employees at Golding does not exceed 500, either in its function as a financial market participant or as a financial adviser or on a consolidated basis, so there is no legal obligation to consider the principal adverse impacts (PAI) of investment decisions on sustainability factors.
As a result, Golding has decided in its function as a financial market participant and financial adviser not to consider the PAI of investment decisions on sustainability factors at the entity level at the present time on the basis of the following considerations.
This is essentially because
- as far as investments in target funds are concerned, the portfolio companies and projects have often not been selected at the time of the investment decision or advice;
- target fund managers, lead investors and portfolio companies that are not directly within the scope of SFDR and/or are domiciled outside the EU cannot generally provide the necessary information (in full);
- the amount of information available at the time of the investment decision or advice depends to a significant extent on the type of investment;
- the EU regulatory framework relating to PAI is still evolving.
The requirements of the PAI are that it is not only necessary to collect the underlying information, but also to manage the resulting outcomes (e.g. by means of limitation and improvements). This is not currently possible in view of the situation described above.
Golding will regularly review its decision not to consider the principal adverse impacts on sustainability factors at entity level on the basis of evolving market practice, regulatory guidance and the availability and quality of data.
Consideration of the principal adverse impacts on sustainability factors at product level
In our role as financial market participant we consider the principal adverse impacts on sustainability factors at product level for selected financial products (i.e. alternative investment funds). The relevant information for these financial products is disclosed in the respective annual report in accordance with Article 11 (2) SFDR.
Integration of sustainability risks in remuneration policies
Avoidance of incentives to take excessive risks
As financial market participant (AIFM) and financial adviser we have defined appropriate remuneration systems that are intended to promote robust and effective risk management of (sustainability) risks, in addition to other objectives. At the same time the remuneration structure should not encourage excessive risk-taking in terms of (sustainability) risks that are not consistent with the strategies of the funds we manage and should be linked to a risk-weighted performance.
To achieve these objectives we have developed transparent remuneration policies that are based on market standards, are adapted to the different departments, functions and levels of responsibility, and take supervisory requirements into account.
Employees are not significantly dependent on variable remuneration
Our employees receive remuneration for their work that is sufficient to reward the professional services they provide in accordance with their capabilities, tasks and responsibilities, their professional knowledge and skills, work experience and seniority and their respective function and region.
It is therefore ensured that our employees are not significantly dependent on variable remuneration and so do not take any disproportionate (sustainability) risks or do not integrate these adequately into their decisions.
Variable remuneration rewards sustainable, long-term results
In addition to their fixed remuneration, our employees may receive variable remuneration in the form of bonus payments. In addition to other remuneration parameters, we therefore use a long-term assessment base and performance against targets agreed with the employee. Depending on the department, function and level of responsibility, the agreed targets may also comprise the appropriate integration of sustainability risks.
Furthermore, the variable remuneration may be granted as a short-term component, which is paid directly after it has been awarded, and a long-term component which is deferred and paid out at a later date. The intention is therefore to reward our employees for the sustainability of long-term outcomes that are the result of decisions taken in the past.
Performance-based profit sharing ensures alignment of interests
Finally, selected employees who as risk owners have a material influence on the entity’s risk profile and that of the funds it manages and advises, are awarded a performance-based profit share (known as “carried interest”) on the basis of long-term performance measurement. This performance-based profit share depends on the investment return of the respective fund and is only paid when the fund investors have earned a defined minimum return on their invested capital.
The profit share is also dependent on a significant personal capital investment in the respective fund by the employee concerned. In this way, their interests are aligned with those of investors, which also ensures that the respective risk owners integrate (sustainability) risks adequately.