Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on sustainability‐related disclosures in the financial services sector (the “SFDR”), Opera Investment Partners AG (the “Sponsor”) ensures that its affiliated entities, which are considered financial market participants under the SFDR (specifically, Opera I General Partner S.à r.l.; the “General Partner”) disclose the manner in which Sustainability Risks are integrated into the investment decisions and the results of the assessment of the likely impacts of Sustainability Risks on the returns of its managed funds (the “Funds”) at entity and product level.

“Sustainability Risk” is defined as 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 investments made by the Funds.  Such risk is principally linked to climate-related events resulting from climate change (a.k.a. physical risks) or to the society’s response to climate change (a.k.a. transition risks), which may result in unanticipated losses that could affect the Funds’ investments and financial condition.  Social events (e.g., inequality, inclusiveness, labor relations, investment in human capital, accident prevention, changing customer behavior, etc.) or corporate governance shortcomings (e.g., recurrent significant breach of international agreements, bribery issues, products quality and safety, selling practices, etc.) and remuneration policy shortcomings may also translate into Sustainability Risks.

The impacts following the occurrence of a Sustainability Risk may be manifold and they vary depending on the investment strategy, region and other factors.

Examples of the possible impact of a Sustainability Risk on the results of the Funds include, inter alia, changing regulations on energy rules or polluting substances, issues regarding employment conditions.

In general, a Sustainability Risk in respect of an asset could result in a negative impact on the return of the asset and/or its value.

Such Sustainability Risks are integrated into the investment decision-making and risk monitoring at the level of each Fund, to the extent that they represent a known potential or actual material risk and/or opportunity to maximizing the long-term risk-adjusted returns.

The SFDR additionally requires to disclose whether the Funds promote “Sustainability Factors”, defined as environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

The Sponsor and the General Partner believe that the kind of investments that are pursued by the Funds, especially when investing in growth opportunities, may serve as a powerful catalyst for the pursuit of sustainable goals.  The Sponsor and the General Partner also believe that businesses that espouse a responsible investment approach are best placed to reach long-term value creation for all of their stakeholders, achieve superior long-term performance and provide attractive returns for investors.

Nonetheless, the Sponsor and the General Partner do not currently take into account the EU criteria for environmentally sustainable economic activities, determined by Regulation (EU) 2020/852 of the European Parliament and of the Council of June 18, 2020 on the establishment of a framework to facilitate sustainable investment, as amended from time to time. 

Nor does the Sponsor or the General Partner specifically consider the principal adverse impacts of the Funds’ investment decisions on Sustainability Factors (in accordance with article 4(1)b) SFDR), as there is no sufficient data available in satisfactory quality in order to allow them to adequately assess such potential adverse impact on Sustainability Factors.

Similarly, the Sponsor and the General Partner do not consider the adverse impacts investment decisions on Sustainability Factors by the underlying funds in which the Funds are invested in, given that they are not involved in the investment decisions by the managers of such underlying funds.  The underlying funds may decide to conduct an assessment of the adverse impact of their investment decisions on Sustainability Factors, in which case that is carried out under their responsibility, including disclosure responsibility.

While the Funds do not for the time being explicitly promote Sustainability Factors or maximize portfolio alignment with Sustainability Factors, they may remain exposed to Sustainability Risks and, when possible, aim at integrating them into the investment decision-making and risk monitoring.