Sustainability-related disclosures

Integration of sustainability risks in investment decision‐making process

RSM Fund Management Luxembourg incorporates sustainability risks into its investment selection and ongoing monitoring processes, in compliance with the provisions outlined in Delegated Regulation (EU) No 231/2013 as amended by Commission Delegated Regulation (EU) 2021/1255 as regards the sustainability risks and sustainability factors to be taken into account by Alternative Investment Fund Managers.

RSM Fund Management Luxembourg manages funds with diverse investment strategies, and thus evaluates sustainability risks on a case-by-case basis, considering the unique attributes of each investment. This assessment is conducted for all funds managed by RSM Fund Management Luxembourg, irrespective of whether the funds promote environmental or social characteristics or have sustainable investments as their objective.

It is important to note that while sustainability risks are taken into account, they may or may not have an impact on portfolio construction.

No consideration of adverse impacts of investment decisions on sustainability factors

RSM Fund Management Luxembourg does at present not consider and disclose adverse sustainability impacts in accordance with point (b) of Article 4(1) of SFDR on a “Financial Market Participant” basis. This is due to the absence of (i) sufficient data/information, and (ii) sufficient quality of such data/information for the assessment of potential adverse sustainability impacts at the time of investment and on an ongoing basis. Moreover, RSM Fund Management manages products with a wide variety of investment strategies and underlying assets, both in type of assets and size of investments. The meaningfulness of the data and an assessment of its evolution appear therefore significantly impaired.

However, principal adverse impact policies and statements for certain products or subsets of products may be published hereunder in the future where relevant.

Disclosure regarding the Integration of Sustainability Risks in RSM Fund Management Luxembourg Remuneration Policies

The Remuneration Policy of RSM Fund Management Luxembourg integrates sustainability-related aspects; in particular:

• The criteria for periodically determining individual and collective variable remuneration incentives shall take due account of present and future sustainability-related risk factors;
• The delegated portfolio manager’s remuneration policies shall include appropriate and equivalent provisions in relation to the integration of sustainability risks.

Product specific Sustainability-related disclosures

• BL Private Assets SCA SICAV-RAIF - Decarbonization Fund