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.

Please note that notwithstanding the fact that we may integrate the consideration of sustainability risks into the investment decision making process for a fund, unless disclosed in the relevant fund supplement we do not currently consider the principle adverse impacts of investment decisions on sustainability factors (in the manner specifically contemplated by Article 4(1)(a) of SFDR) given the investment objective, strategy and guidelines of the funds we manage, and how we consider it best to undertake the investment opportunity selection process and achieve the returns sought for our funds.


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.