Langham Hall Luxembourg AIFM - Sustainable Finance Disclosure Regulation

Disclosures for Articles 3, 4 and 5 of SFDR

This disclosure is made for the purposes of Articles 3, 4 and 5 of EU Regulation 2019/2088, known as the Sustainable Finance Disclosure Regulation or SFDR.

Article 3 (1) requires an AIFM to publish information about their policies on the integration of sustainability risks in their investment decision-making process.

Article 4 (1) (b) requires an AIFM to disclose clear reasons for why we do not consider adverse impacts of investment decisions on sustainability factors at entity level.

Article 5 (1) requires an AIFM to publish information on the consistency of its remuneration policy information with the integration of sustainability risks.

“Sustainability factors” mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

“Sustainability risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Langham Hall provides its portfolio management services to a large number of different styles of fund strategies, investor requirements and investment universe, each with varying levels of details on the implementation of consideration of sustainability risks into the processes and procedures of service providers that play a part in investment sourcing, due diligence and execution of deals.

Langham Hall is committed to improving the consideration of sustainability risks factors in the investment decision making process of all the funds under its management and oversight. We have implemented new initiatives towards this goal including:

  • Ensuring a specific inclusion in each investment proposal on whether sustainability risks has been considered (and if so, including and reviewing details of such considerations and the due diligence or reports have been undertaken to investigate such risks);
  • Reviewing the risk management policy and processes to include a specific risk assessment on sustainability risks;
  • Encouraging attendance at seminars and workshops for portfolio and risk management staff to understand and implement better the SFDR requirements and the underlying principles it aims for, as well as wider ESG initiatives and market evolution and benchmarks;
  • Encouraging continuous improvement in the integration of consideration of sustainability factors in the processes and procedures of service providers to our funds;
  • Reviewing market practice for best of breed practices and promoting these within the funds that we manage;
  • Reviewing voluntary industry codes to encourage service providers to our funds to consider adherence and reviewing our own internal processes and business model with a view to voluntary adherence; and
  • Raising more awareness of ESG matters within the operations of the company to engender a responsible investment culture.

Langham Hall does not currently consider adverse impacts of investment decisions on sustainability factors at entity level. This is because the final investment decisions by us across our funds take into account a broad range of factors with the aim of achieving the optimum outcome for its investors within the stated investment objectives and restrictions for each fund, and over the different time horizons. The methodology for considerations of adverse impacts on sustainability factors for these wide range of factors are difficult to implement at the entity level at this present time.

On a fund by fund basis, the pre-contractual disclosures provided to each investor will set out if there is specific consideration of sustainability risks and consideration of the adverse impacts of investment decisions for that particular fund. We aim to continue to work with each fund to embed these more fully subject to each fund’s investment objectives and restrictions over life of the funds that we manage. We expect this will be a work in progress until the industry is more evolved in the methodology of measuring and reporting these in a way that is useful for investors.

Langham Hall does not promote risk taking in its remuneration policy. No individual staff member’s remuneration is linked to the economic performance of the funds under management.

Langham Hall will continue to review the above positions as the industry evolves and any material amendment to the approach will be updated on the website in accordance with the SFDR.

Article 8 or Article 9 additional Fund Disclosures: Clarion Partners EuropeImpax Asset Managment.

Last reviewed March 2021.