The Sustainable Finance Disclosure Regulation (SFDR) – Regulation (EU) 2019/2088 – requires the disclosure of specific information by financial market participants and investment advisors regarding the integration of sustainability risks, the consideration of principal adverse impacts, and the disclosure of sustainability-related information at the level of financial products and services.
In this context, and in compliance with the provisions of Article 12 of Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022, regarding the disclosure of sustainability-related information in the financial sector, ROCKMARK ASSET MANAGEMENT – SGOIC, S.A. informs that it does not, at present, take into account any adverse impacts on sustainability factors in its investment decisions.
Without prejudice to its diligent and prudent conduct under the mandates assigned to it pursuant to the management regulations, RockMark does not consider the adverse impacts of investment decisions on sustainability factors for the following reasons:
– It does not manage CIUs that fall within the scope of Article 8 or Article 9 of the SFDR.
– The underlying investments of the CIUs under management do not take into account the European Union criteria applicable to environmentally sustainable economic activities.
– Considering the type of investments made by our CIUs and the level of publicly available information on ESG matters, in particular regarding the indicators listed in Annex I of Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022, such information is insufficient, which prevents a reasonable and adequate consideration of the adverse impacts of investment decisions on sustainability factors based on that information.
– Given the lack of sufficient public information sources in this regard, the consideration of the adverse impacts of investment decisions on sustainability factors would require obtaining such information externally, whether through service providers or investee companies. However, even through these means, it is anticipated that in many cases the available information would be insufficient, considering the companies in which investments are typically made.
Thus, not only would this process entail excessive and disproportionate costs for RockMark, its CIUs, and its clients/investors, but it would also fail to ensure the necessary outcome for the effective consideration of such adverse impacts.
Should the circumstances described above change in the future, RockMark may reconsider this matter and, in such case, will duly and timely inform its investors and other stakeholders of any changes, although it is not possible at this time to anticipate a specific date for such effect.
(For more information, please refer to the Portuguese version of this document.)