Sustainability-related disclosures

Sustainability Risk Policy Statement

Last updated: January 2025

Background and Scope

Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“the SFDR”), is part of a broader legislative package under the European Commission’s Sustainable Finance Action Plan. The SFDR requires firms to make strategic business and policy decisions regarding their approach to ESG which must be disclosed on the firm’s website and in pre-contractual and periodic disclosures. ESG stands for ‘Environmental, Social and Governance’ and covers a number of areas, including: climate, energy use, availability of raw materials, health, security, human rights, labour laws, and corporate governance.

The SFDR applies at the firm level, to “Financial market participants (FMP)” which includes AIFMs, UCITS management companies, MiFID investment firms, and the product level (or “Financial products (FP)” as defined within the SFDR.

Article 3 of the SFDR, requires a financial market participant to ”publish on their websites information about their policies on the integration of sustainability risks in their investment decision‐making process.” Waystone (being those entities listed in Appendix 1 below) have adopted this statement to describe the approach taken to demonstrate compliance with Article 3 of the SFDR. The Waystone Entities also have specific entity level Policies which are linked hereunder.

Integration of sustainability risks

Waystone acknowledges the impacts that sustainability risks can impose on the funds managed and considers the approach to integrate the risks stemming from sustainability issues described in this policy as strengthening its fiduciary duties towards the investors of the funds managed.

Detailed entity specific information on Waystone’s approach to integrate sustainability risks into the investment decision making process can be found in the dedicated policy which has been set-up in compliance with the requirements, which is available here.

Principle adverse impact (PAI) statement

No consideration of adverse impacts of investment decisions on sustainability factors

In accordance with the Sustainable Finance Disclosure Regulation (SFDR), specifically Articles 4 and 7, which stipulate requirements for disclosures regarding sustainability risks and the consideration of Principal Adverse Impacts (PAI), Waystone presents the following statement concerning its current approach to PAI. At this time, Waystone does not consider the adverse impacts of investment decisions on sustainability factors. As a UCITS Management Company and Alternative Investment Fund Manager (AIFM) for a diverse range of funds (the “Funds”), Waystone typically delegates investment management responsibilities to external portfolio managers (“Investment Manager(s)”). In light of the diverse methodologies applied to environmental, social, and governance (ESG) considerations in respect of each Fund, Waystone has determined that the aggregation at entity level of PAI reporting carried out by individual Investment Manager in respect of individual Funds (where applicable) is of no demonstrable value to individual stakeholders or investors, and, as such, Waystone has determined not to integrate adverse impacts arising from its investment decisions on sustainability at the entity level. Nevertheless, recognising the various investment strategies employed by the Funds, which exhibit differing levels of focus on ESG considerations, PAI may be evaluated on a case-by-case basis at the Fund level at the discretion of the Investment Manager.

In circumstances where Waystone retains portfolio management responsibilities, it may consider PAI for the relevant funds, contingent upon the implementation of equivalent measures and appropriate disclosures on Waystone’s website. Furthermore, Waystone acknowledges that, in certain instances, Investment Advisors may disseminate information related to PAI on their respective websites for the relevant funds.

This position will remain under continuous review, with consideration given to evolving market practices and regulatory developments. Waystone will periodically reassess the integration of sustainability risks, PAI statements, and associated policies, as well as the reporting requirements for the funds it manages, to ensure their ongoing appropriateness. These statements are subject to at least annual review.

Remuneration policy

The SFDR requires financial market participants to integrate information on the consistency of their remuneration policy with the integration of sustainability risks, in accordance with Art. 5 I of the SFDR.

Waystone has amended its remuneration policy accordingly. Additional information for each of the Waystone entities can be found here.

Pre-contractual information

All required information at a product level can be found in the specific pre-contractual information of the product (e.g. sales prospectus; private placement memorandum).

Appendix 1:

Waystone Management Company (IE) Limited
Waystone Management Company (IE) Limited – Luxembourg Branch
Waystone Fund Management (IE) Limited
Waystone Investment Management (IE) Limited
Waystone Management Company (Luxembourg) S.A.

Article 10 Website Disclosure

As further detailed below, this statement is issued for information purposes only, it is not intended as investment advice and is not an offer or a recommendation and should not be used as the basis for any investment decision.

Article 10 of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector, as amended (“SFDR”) requires certain EU-regulated entities to disclose information on a public website regarding financial products which promote environmental or social characteristics, or which have sustainable investment as their objective. This Information Statement has been prepared for the purpose of meeting the website disclosure requirements in Article 10 of SFDR.

These disclosures constitute the transparency disclosures with respect to certain Schemes managed by the Waystone Entities for the purposes of Article 10 of SFDR. The Waystone entities (listed above) are authorised by the Central Bank of Ireland and the Commission de Surveillance du Secateur Financier respectively to provide UCITS Management Company/AIFM services to a range of UCITS/AIFs domiciled in Ireland and Luxembourg (the “Schemes’’/ ‘’Funds”). The Waystone Entities typically delegate the portfolio management function to a suitably qualified third-party investment manager (the “Delegated Manager”). In certain instances, the Waystone Entities may retain the portfolio management function. In both cases, the Waystone Entities are required to provide transparency on how they integrate sustainability considerations into the investment process with respect to the investment funds they manage. In line with Article 10 of SFDR, financial market participants are required to publish and maintain certain information for each financial product referred to in Article 8(1) and Article 9(1), (2) and (3).

The purpose of this Statement is to disclose the location of the above information in respect of the Schemes to which the Waystone Entities act as UCITS Management Company/AIFM which have been designated as an Article 8 or an Article 9 product for the purposes of SFDR. The detailed information required under Article 10 of the SFDR is set out in the private placement memorandum and/or other pre – contractual materials for each of the Funds managed.

If you have any queries in relation to disclosures related to a financial product or the Waystone entities, please Contact Us.