This declaration of no consideration of the negative impacts on sustainability factors complies with the provisions of article 4, paragraph 1, subparagraph b) of the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation – SFDR Regulation) and article 12 of the Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022.
For the purposes of SFDR Regulation, “sustainability factors” mean environmental, social and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters (§ 24 of article 2.º of the SFDR Regulation).
GM does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFD Regulation, as:
- the constitutive documents as the funds managed by GM funds do not require the investment in sustainable products, neither require due diligence on sustainability factors, leading to participants with no expectations on the consideration of the negative impacts that sustainability risks may cause.
GM shall respect the management mandate given by the participants in the private equity funds, as well as the respective investment policies and objectives, consequently the decisions on behalf of the private equity funds, even the ones related to sustainability, must comply and be compatible with the management mandates and the private equity funds investment policies.
- The consideration of the impacts implies large costs for GM.
- The current regulatory framework on the transparency of the negative impacts on the mentioned factors is not yet complete and the lack of information on standard indicators on these factors, particularly relevant for the respective measurement, makes it very difficult to carry out a complete, effective, and detailed consideration and demonstration of the negative impacts of investment decisions on sustainability factors.
- In accordance with Art. 4 SFD Regulation the publication of Principal Adverse Impact statement is mandatory for financial market participants that exceed an average of 500 employees during the financial year (Art. 4 § 3 SFD Regulation). GM has less than 500 employees.
