SFDR DISCLOSURE
As a self-managed alternative investment fund, Frilsham is subject to Regulation (EU) 2019/2088, also known as the Sustainable Finance Disclosure Regulation or SFDR, which sets out requirements relating to sustainability‐related disclosures in the financial services sector, as applicable to ‘financial market participants’ such as Frilsham.
Following a sustainability risk assessment, Frilsham has determined that it does not restrict the investment objectives and policies to investments which require the integration of sustainability risks in Frilsham’s decision-making processes.
Frilsham believes that its responsibility is to endeavour to allocate capital responsibly in the shares of companies that It understands are seeking to operate within the law; it does not consider appropriate for fund managers to attempt to police the applicable laws. Notwithstanding, it remains Frilsham’s policy to perform an ongoing assessment of its products to ensure the suitability thereof for the identified target market.
The Frilsham Europe Equity Fund does not hold itself out to be a fund which actively promotes environmental or social investing in its investee companies, and does not take account of Principal Adverse Impacts in its investment process.