MY.Alpha Management HK Advisors Limited
ENTITY LEVEL WEBSITE DISCLOSURES PURSUANT TO ARTICLES 3, 4 AND 5 OF THE EU SUSTAINABLE FINANCE DISCLOSURE REGULATION (2019/2088) (SFDR)
As MY.Alpha Management HK Advisors Limited (the “AIFM”) manages certain alternative investment funds (the “Funds”) registered for marketing under the Alternative Investment Fund Managers Directive (2011/61/EU) (the “AIFMD”) in one or more member states of the European Economic Area (“EEA”), the AIFM is required by the Sustainable Finance Disclosure Regulation (Regulation 2019/2088) (the “SFDR”) to make certain disclosures on its website, including information about the AIFM’s policies on the integration of sustainability risks into its investment decision-making process; its approach to adverse sustainability impacts; and the consistency of its remuneration policies with the integration of sustainability risks. For these purposes, 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.
No consideration of sustainability adverse impacts
The AIFM does not currently consider adverse impacts of investment decisions on sustainability factors as the Funds are not designed to be environmental, social and governance (“ESG”) focussed investment products. The AIFM’s primary focus is therefore achieving attractive risk-adjusted investment results for the Funds. The AIFM acknowledges that the pursuit of the Funds’ objectives may, in some circumstances, have an adverse impact on sustainability factors but the AIFM does not take account of such impacts in its management of the Funds.
Policies on the integration of sustainability risks into the investment decision-making process
When considering an investment, the AIFM will, if deemed appropriate by the relevant investment professional and taking account of the nature of the proposed investment and the AIFM’s policy on sustainability risks, undertake due diligence on potential investments and consider sustainability issues and metrics as a factor in the analysis with respect to prospective investment returns.
The AIFM works with outside research providers, where relevant, to enable analysts to review data in order to aid the analysis of sustainability risks associated with prospective investments in relevant securities.
Sustainability risks consist of one category of risk among others taken into account by the AIFM, including market, liquidity and counterparty risks, when making investment decisions. The AIFM assesses, as applicable, the items set forth below in connection with a prospective investment opportunity on the basis that poor outcomes in respect of such matters can be indicative of an issuer’s susceptibility to longer term sustainability risks. The AIFM’s investment team weighs sustainability risks alongside other relevant risk factors, when making investment decisions.
The Manager may take into account when relevant:
• Compliance with applicable national, state and local laws.
• Environmental considerations.
• Occupational safety and consumer safety.
• Respect for human rights, including processes for and measures for preventing the use of child labor.
• Anti-bribery and anti-corruption policies and procedures.
• Governance structure and policies of the issuer.
The AIFM continues to evaluate sustainability risks of investments throughout the period of ownership by the Funds.
In 2016, The AIFM established an ESG Committee to provide oversight for socially responsible investing. The Committee meets quarterly and establishes and updates the AIFM’s ESG policies and programs, supports the investment teams, raises the AIFM’s awareness of ESG initiatives, conducts training for investment professionals, and monitors industry trends.
Consistency of remuneration policies
The AIFM’s remuneration policies are consistent with its approach to the integration of sustainability risks into the investment decision making process. As sustainability risks are a type of financial risk, the AIFM acknowledges that failure to consider such risks could have an adverse impact on the performance of investments and the AIFs. Pursuant to the AIFM’s current remuneration policies, the AIFM awards fixed and variable remuneration to staff. Variable remuneration is awarded on a discretionary basis and takes into account the performance of an individual employee, the performance of the AIFs, and the overall financial performance of the AIFM. Accordingly, to the extent that sustainability risks have an adverse impact on performance of the AIFs, this is likely to be reflected in the overall level of variable remuneration awarded to entire staff.