ESG

Information Statement

on our Policy on

the Integration of Sustainability Risks in the Investment Decision Making Process

 

Issued by Brilliance Asset Management Limited with respect to Brilliance Asset Management ICAV

 


Sustainable Finance Transparency

The European Union has introduced a series of legal measures (the primary one being the Sustainable Finance Disclosures Regulation (Regulation (EU) 2019/2088)) requiring firms that manage investment funds to provide transparency on how they integrate sustainability considerations into the investment process with respect to the investment funds they manage.


Our Approach to Sustainable Investment

We believe that investors, and asset managers that invest on their behalf, have a responsibility to make their investments in a way that effectively supports a sustainable society.

At the core of our commitment to help our clients achieve their financial objectives is a conviction that this can be achieved by investing responsibly.

We value the importance of integrating Environmental, Social, and Governance (ESG) factors into our investment and risk processes and fundamentally believe that this is aligned with the aim of achieving long-term positive financial performance for our investors. We also recognise and value the fact that this will also support the better functioning of companies we invest in, enhancing behaviour in a wide range of markets and industries and having a positive societal impact beyond the financial markets.


What is a Sustainability Risk?

In this context a sustainability risk is considered to be 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 an investment.


Information on How we Integrate Sustainability into the Investment Decision Making Process

As part of the process to undertake appropriate due diligence on investments we evaluate and integrate sustainability risks and other relevant ESG factors when making investment decisions. We utilise internal and external resources to assist in analysing ESG factors, which are systematically integrated into the investment process when we believe they could have a material impact on a company's valuation or financial performance. As part of the investment process we assess a company's corporate governance practices, according to local laws, regulations and established guidelines. In addition, we may refer to the OECD Principles of Corporate Governance, which represent widely accepted standards for corporate governance in many countries. Our proprietary research incorporates an analysis of governance and environmental impact on the valuation of a company. While ESG factors are incorporated into the investment decision making process they also form part of our engagement with investee companies.

In respect of each sub-fund, our investment approach and decision making processes are based on clearly defined investment objectives, investment policies, investment strategy, investment restrictions and risk management parameters, as contained in the prospectus.

For more details, please refer to the investment strategy of the relevant sub-fund as set out in the prospectus and associated investor materials.


Further Information

This Information Statement is issued for information purposes only.

This Information Statement is not intended as investment advice and is not an offer or a recommendation about managing or investing assets and should not be used as the basis for any investment decision.

The information contained herein is current as of the date of issuance and is subject to change without notice.

We do not make any express or implied warranties or representations as to the completeness or accuracy or accept responsibility for errors.

No risk management technique can guarantee the mitigation or elimination of risk in any market environment.


Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value.  All investments involve risk, including the possible loss of capital.




Information Statement

on our Policy on

the Consideration of Principal Adverse Impacts of Investment Decisions on Sustainability Factors

 

Issued by Brilliance Asset Management Limited with respect to Brilliance Asset Management ICAV

 

Sustainable Finance Transparency

The European Union has introduced a series of legal measures (the primary one being the Sustainable Finance Disclosures Regulation (Regulation (EU) 2019/2088), "SFDR") requiring firms that manage investment funds to provide transparency on how they integrate sustainability considerations into the investment process with respect to the investment funds they manage.

This Information Statement has been prepared for the purpose of meeting the disclosure requirements in Article 4 of SFDR, that is, specifically, the disclosure requirements applicable to us as a firm with regard to whether and how we consider principal adverse impacts of investment decisions on sustainability factors.

It is noted that the regulatory technical standards ("RTS") to specify the details of the content, methodologies and presentation of the information to be disclosed under Article 4 of SFDR have been delayed and will not be issued when the relevant disclosure obligations in SFDR become effective.

It is noted that the European Commission has recommended that from the effective date of SFDR, firms are recommended to comply with the specific disclosure obligations in SFDR that are reliant on RTS on the basis of a high-level, principles-based approach.

We therefore seek to comply on a best efforts basis with the relevant disclosure obligations and issue this Information Statement as a means of achieving this objective.

It is expected that this Information Statement will be reviewed and updated once the relevant RTS come into effect, noting in particular, that the RTS are expected to contain details on the content, methodologies and presentation of the information to be disclosed and this could therefore require a revised approach to how we seek to meet the SFDR disclosure obligations.

The Information Statement may also be updated to take account of the Regulation on the Establishment of a Framework to Facilitate Sustainable Investment (Regulation EU/2020/852, the "Taxonomy Regulation") once it comes into effect (1 January 2022).


Our Approach to Sustainable Investment

We believe that investors, and asset managers that invest on their behalf, have a responsibility to make their investments in a way that effectively supports a sustainable society.

At the core of our commitment to help our clients achieve their financial objectives is a conviction that this can be achieved by investing responsibly.

We value the importance of integrating Environmental, Social, and Governance ("ESG") factors into our investment and risk processes and fundamentally believe that this is aligned with the aim of achieving long-term positive financial performance for our investors. We also recognise and value the fact that this will also support the better functioning of companies we invest in, enhancing behaviour in a wide range of markets and industries and having a positive societal impact beyond the financial markets.

 

What is a Sustainability Risk?

In this context a sustainability risk is considered to be 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 an investment.


Information Regarding the Consideration of Principal Adverse Impacts of Investment Decisions on Sustainability Factors

We currently do not consider the adverse impacts of investment decisions on sustainability factors. The rationale for not considering such adverse impacts is based primarily on the fact that, as outlined above, the RTS which will set out the content, methodology and information required in the principal adverse impacts statement remain in draft form and have been delayed. We may consider the principal adverse impacts of investment decisions on sustainability factors once the RTS come into effect, in which case this Information Statement will be updated.


Further Information

This Information Statement is issued for information purposes only.

This Information Statement is not intended as investment advice and is not an offer or a recommendation about managing or investing assets and should not be used as the basis for any investment decision.

The information contained herein is current as of the date of issuance and is subject to change without notice.

We do not make any express or implied warranties or representations as to the completeness or accuracy or accept responsibility for errors.

No risk management technique can guarantee the mitigation or elimination of risk in any market environment.


Past performance is not a guarantee or a reliable indicator of future results and an investment could lose value.  All investments involve risk, including the possible loss of capital.