As third party alternative investment fund manager, Royalton Partners S.A. (“RPSA”) highly encourages but does not apply specific environmental, social or governance (ESG) principles at company level. ESG criteria depend on the different type of funds which Royalton Partners manages and which may apply specific ESG approach.

For all funds for which it acts as alternative investment fund manager, RPSA has implemented processes so that at least sustainability risks are taken into account in the investment decision-making process and the risk management framework. The below describes the minimum approach adopted by RPSA with respect to the integration of sustainability risks:

(i)                  when RPSA relies on an investment advisor, RPSA will assess how sustainability risks are integrated in the investment research of such advisers [1]. In addition, RPSA will carefully review any analysis on sustainability risks in the context of an investment recommendation made by an investment advisor;

(ii)                RPSA integrated sustainability risks in its own policies such as for example the portfolio management procedures and the risk management process; and

(iii)               RPSA integrated sustainability risks in its initial and on-going due diligence questionnaires and ongoing oversight.

Currently, RPSA does not consider the adverse impacts of its investment decisions on sustainability factors, as RPSA considers that for the time being, it does not have sufficient guidance to do so in view of the fact that the regulatory technical standards to be issued in the context of Regulation 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”) are not yet  in final form. RPSA might reconsider its position in the future depending also on its and its clients’ willingness to consider the adverse impacts on their investment decisions on sustainability factors.

RPSA will at all times ensure that its remuneration policy is consistent with the integration of sustainability risks and will notably ensure that when determining the variable remuneration of the identified staff, the board takes into account compliance of the relevant staff member with all procedures and policies of the company, including those relating to the integration of sustainability risks. It shall in this regard be noted that as of today, our remuneration policy already seeks to: (i) align the staff’s incentives with asset owners’ long-term interests and the long-term success of RPSA; and (ii) to promote a sound and effective risk management culture to protect the value of the investment portfolio. Integration of ESG/sustainability risk considerations, where these are relevant and material for investment performance, are already taken into account by these existing requirements as it should be seen and used as an instrument to enhance investment performance, which would equally benefit the funds (and their investors), RPSA and its employees.

[1] With respect to AEW Value Investors Asia IV, L.P., AEW Value Investors Asia V, L.P., AEW Asia Pacific Real Estate Fund, L.P. and AEW Core Property (U.S.) Lux Parallel, L.P. please see additional information at https://www.aew.com/socially-responsible-investment

[2] With respect to Lendable S.A. SICAV-RAIF, please see additional information at https://lendable.io/wp-content/uploads/2021/12/Website-disclosure-SFDR-Article-10.pdf

[3] With respect to U-Prime Real Estate SICAV-RAIF, please see additional information at https://www.ubp.com/en/investment-expertise/responsible-investment. As additional point be advised that the SFDR RTS Pre-Contractual Template and the Fund Documentation are available to the investors upon request to the AIFM and/or the Investment Advisor.

RPSA implemented adequate and effective policies and procedures for implementing:

– complaints handling policy,

– conflict of interest policy,

– best execution policy,

– voting rights policy,

– remuneration policy

and

– independent analysis of investment transactions.

These procedures are available for inspection by investors of the funds managed by RPSA at the registered office of the Company or provided upon request by email. The request should be sent to compliance@royalton-partners.com