Partners Group (Luxembourg) S.A. – SFDR entity disclosure
Art. 3. Integration of sustainability risks in Partners Group’s investment decisions
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (the “Disclosure Regulation”) aims at providing more transparency to investors on sustainability risk integration, on the consideration of adverse sustainability impacts in the investment processes and on the promotion of environmental, social and/or governance (“ESG”) factors.
In particular, it requires financial market participants to publish on their websites information concerning their policies on the integration of sustainability risks in their investment decision‐making process.
Partners Group as a global private markets player recognizes for funds it manages that various sustainability risks may potentially affect the value of investments at individual asset level and portfolio level. These sustainability risks are environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the funds’ portfolio and the returns of the funds. Environmental risk factors could be (without limitation) events like earthquakes, climate change, flood risk or other environment-related factors. Social risk factors could be circumstances like social unrest, changes to social or labor laws or other social factors, and governance risks could be factors like bribery and corruption, compliance risks or similar. Sustainability risks that could occur and which might potentially affect the performance of the funds may vary from one investment to another and no exhaustive list can be given, and these risks will also vary from time to time.
Partners Group Luxembourg S.A. includes sustainability risks in its general investment decision-making process. Where Partners Group Luxembourg S.A. delegates portfolio management to other Partners Group entities, the investment teams are generally responsible for following relevant sustainability processes as applicable. Partners Group as a group strives to mitigate sustainability risks and create value by acting on sustainability opportunities.
Partners Group Luxembourg S.A.’s affiliates which act as delegated portfolio managers are generally considering materially relevant sustainability risks into their investment process alongside with other material factors. The degree to which sustainability risks will be taken into account may vary from one product to another and may depend on the product scoping and concrete structuring of each individual product. Partners Group utilises both proprietary ESG tool and external sources for evaluating the sustainability risk profile of potential investments. Partners Group is also taking guidance from the UN Principles for Responsible Investment (PRI) in including ESG issues in the analysis and decision-making processes in investment advice.
Further information of Partners Group’s ESG & Sustainability Directive can be found on the group’s website at https://www.partnersgroup.com/en/sustainability/.
Art 4: No consideration of sustainability adverse impacts / Transparency of adverse sustainability impacts at entity level
Pursuant to the Disclosure Regulation, financial market participants shall publish on their websites information about whether or not they consider principal adverse impacts of investment decisions on sustainability factors.
No consideration of sustainability adverse impacts:
At this stage, Partners Group does not consider the principal adverse impacts of its investment decisions on sustainability factors, because the EU regulatory technical standards required in relation to adverse impact assessment are not yet available in final form.
However, Partners Group continues to review and consider its obligations with respect to whether it considers principal adverse impacts of investment decisions on sustainability factors. In particular, Partners Group awaits the further consultation and/or guidance on the Level 2 regulatory technical standards (the “RTS”), and the finalisation of the RTS, which are expected to enter into force during 2022. The decisions and disclosures in relation to the RTS will be made taking into account the deadlines of the Disclosure Regulation (SFDR), as required.
Art 5. Transparency of Partners Group’s remuneration policies in relation to the integration of sustainability risks
Pursuant to the Disclosure Regulation, financial market participants are required to disclose on their websites how their remuneration policy is consistent with the integration of sustainability risks.
To the extent any members of Identified Staff (as defined by applicable law) are directly taking investment decisions on behalf of alternative investment funds managed by Partners Group Luxembourg S.A., their individual performance evaluation may include considerations on how such Identified Staff member(s) have, during the relevant performance period, integrated and complied with the disclosures on sustainability risks as laid down in the relevant alternative investment funds' constituent / offering documents. With regard to fund’s whose portfolios are managed by third parties, and to whom Partners Group Luxembourg S.A. has delegated such activities, Partners Group Luxembourg S.A. will enquire if the delegate is subject to regulatory requirements on remuneration which are similar to those applicable to Partners Group Luxembourg S.A. under the Disclosure Regulation or will otherwise use commercially reasonable efforts to oblige the delegate to comply with remuneration principles which reflect such requirements by contract.