Sustainable Risk Finance Disclosure Regulation (2019/2088) (the “Disclosure Regulation”)
PAI makes the following disclosures in accordance with Articles 3(1), 4(1)(b) and 5(1) of the Disclosure Regulation.
Sustainability risk policies
A sustainability risk means “an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment”. In the context of PAI, sustainability risks are risks which, if they were to crystallise, would cause a material negative impact on the value of the portfolios of PAI’s funds.
Before any investment decisions are made on behalf of any funds that PAI manages, PAI will have completed a process that identifies the material risks associated with each such proposed investment; these will include relevant and material sustainability risks. Consideration of all these risks is part of the risk management processes of PAI relating to the relevant fund, starting with an overall assessment of the likely risks associated with investments pursuant to the relevant fund’s investment policy and objectives and leading to specific investment proposals submitted to PAI’s investment committee. The investment committee assesses all the identified risks alongside other relevant factors set out in the proposal. Following its assessment, the investment committee makes relevant investment decisions having regard to the relevant fund’s investment policy and objectives. Sustainability risks then continue to be assessed throughout the holding period of investments and during the divestment phase.
No consideration of sustainability adverse impacts
PAI does not consider the principal adverse impacts of its investment decisions on sustainability factors in the manner prescribed by Article 4 of the Disclosure Regulation.
Article 4 of the Disclosure Regulation requires fund managers to make a clear statement as to whether or not they consider the “principal adverse impacts” of investment decisions on sustainability factors. Although PAI takes sustainability and ESG very seriously, it uses its own procedures, policies and metrics to assess the adverse impacts of investment decisions on sustainability factors which to not align with those prescribed under Article 4 of the Disclosure Regulation, as PAI considers that these are more appropriate and tailored to PAI and investments that PAI makes on behalf of its funds, and therefore assist in PAI’s objective to deliver long-term risk adjusted returns to investors.
Accordingly, PAI does not currently intend to consider the prescribed adverse impacts of their investment decisions on sustainability factors within the meaning of Article 4 of the Disclosure Regulation; however, PAI keeps this situation under ongoing review.
PAI pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff takes into account compliance with all PAI’s policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process.