ESG Disclosure

ESG responsibility

Cloudbreak Sarl views environmental, social and governance (ESG) factors as important for making sound investment decisions in the funds under management.

Provisions of the Sustainable Finance Disclosure Regulation (EU) 2019/2088 (SFDR)

Cloudbreak makes the following disclosures in accordance with Articles 3(1) and 4(1)(b) of the SFDR.

Consideration of sustainability adverse impacts

Adverse sustainability impacts relate to the risk that investments made via the funds managed by Cloudbreak Sarl (the Luxembourg AIFM), in its capacity as an alternative investment fund manager, may have on sustainability factors. The Luxembourg AIFM believes that considerations concerning sustainability factors play a crucial role in being a responsible alternative investment funds manager and are a key driver in creating long-term value for stakeholders and society by making its business and the managed assets future-proof. Nevertheless, pursuant to Article 4.1(b) of the SFDR, the Luxembourg AIFM does not consider the adverse impacts of investment decisions on the basis that, in the context of the current investment strategies of the funds under management, it does not integrate in its processes any due diligence on the principal adverse impacts of the investment decisions. However, the Luxembourg AIFM intends to review its position in line with market expectations during the year.

Approach to sustainability risk

A sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment. To the extent that ESG factors represent material risks and/or opportunities to maximise long-term risk-adjusted returns, they may be considered as part of investment decision-making. Nevertheless, the Luxembourg AIFM has decided that taking into consideration sustainability risks for the current returns of the investments is temporarily not relevant for its investment strategy.