Sustainability-Related Disclosures
EU Regulation 2019/2088 (Regulation on Sustainability-Related Disclosures in the Financial Sector, SFDR) aims, among other things, to increase transparency regarding how financial market participants integrate sustainability risks into their investment decisions. By establishing harmonized requirements for sustainability-related information, the comparability between financial products can be improved.
Under SFDR, there are four different categories of funds:
- Funds with sustainability or carbon emission reduction as its objective (Article 9)
- Funds that promote environmental or social characteristics (Article 8)
- Funds that integrate sustainability risks into investment decisions, but do not promote environmental or social characteristics or have a sustainability or carbon emission reduction objective (Article 6)
- Funds where sustainability risks are not relevant (Article 6)
Atle Fund Management currently manages funds in categories 1 and 2 (SFDR Articles 8 and 9).
Statement on Principal Adverse Impacts on Sustainability Factors
Sustainability factors are environmental, social, or employee matters, respect for human rights, and anti-corruption and anti-bribery issues.
According to SFDR’s Article 4, financial market participants must publish and keep updated on their website a statement on whether and how the principal adverse impacts of investment decisions are considered or, alternatively, that they are not considered. This statement applies at the entity level, i.e., the company. Article 7 states that information must be provided on whether and, if so, how principal adverse impacts on sustainability factors are considered for a specific financial product.
The company currently does not consider the principal adverse impacts of investment decisions at the entity level.
The reason for this position is Atle Fund Management’s business model and the fund management services we offer our clients. The company currently offers a broad range of funds covering multiple investment strategies. These funds are managed either by Atle Fund Management itself or by external portfolio managers (clients of Atle Fund Management) under the company’s license. The sustainability work is based on a minimum sustainability standard required of all our funds, but beyond that, it varies across funds. It is the responsibility of each portfolio manager to integrate sustainability in a way that is relevant and value-creating for the fund they manage.
A fund that has sustainable investments as its objective (Article 9) must, as part of the disclosures related to the “do no significant harm” principle, also consider principal adverse impacts. Other funds may choose to consider principal adverse impacts as a way to promote environmental or social characteristics. At the product level, this means that some portfolio managers will consider the principal adverse impacts of investment decisions for the fund(s) they manage, while others will not.
Given the diversity of strategies and fund types under the management of Atle Fund Management, we have deemed it appropriate to accommodate both approaches.
Portfolio Managers Who Consider Principal Adverse Impacts in Fund Management
If the portfolio manager considers principal adverse impacts on sustainability factors for a fund, Atle Fund Management shall ensure that the manager has appropriate policies in place to identify and prioritize principal adverse impacts and sustainability indicators. The company shall also ensure that the manager has adequate infrastructure in place to regularly report on the chosen sustainability factors, that the fund’s prospectus contains accurate and appropriate information on how principal adverse impacts on sustainability factors are considered, and that adequate information is published on our website. Furthermore, the manager’s processes and approaches to sustainability factors shall be subject to continuous monitoring. The company shall also ensure that the fund’s periodic reports contain the necessary information regarding the consideration of principal adverse impacts on sustainability factors.
Portfolio Managers Who Do Not Consider Principal Adverse Impacts in Fund Management
When a portfolio manager does not consider principal adverse impacts on sustainability factors, the company shall ensure that accurate information is provided in the fund’s prospectus.
Sustainability-Related Disclosures for the Company’s Funds
Our portfolio managers work independently with the funds offered by Atle Fund Management. This also applies to the integration of sustainability aspects in fund management. Information on sustainability risks and the methods used in investment decisions for funds in Atle Fund Management’s offering is available here (in Swedish) and in each fund’s prospectus:
Humle Fonder (clients of Atle Fund Management)
- Humle Småbolagsfond - see the Sustainability Disclosures on the fund page.
- Humle Sverigefond - see the Sustainability Disclosures on the fund page.
HealthInvest Partners
- HealthInvest Sustainable Healthcare - see the Sustainability Disclosures on the fund page.
- HealthInvest Alpha Fund - see the Sustainability Disclosures on the fund page.
For more information on how Atle Fund Management exercises ownership with regard to portfolio companies' sustainability efforts, see the Shareholder Engagement Guidelines (In Swedish).
For more information on the principles of the company’s remuneration system and how sustainability risks are considered in the remuneration system, see the Remuneration Policy (In Swedish).