Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Art 12 Disclosures – Record of Changes to sustainable Funds
The board of Premium Selection UCITS ICAV met on 18th July 2023 and approved updates to two sustainable sub-funds – those being Polar Capital Future Energy and Columbia Threadneedle Future Environment. It was agreed that the minimum sustainable investment quota for each sub-fund would be changed from 0% to 80%. The supplements for each sub-fund were duly updated and filed with the Central Bank of Ireland.
Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Sustainability Risk Disclosure – Three Rock Capital Management Limited in complying with Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it has implemented a Sustainability Risk Policy. This Policy ensures that all Funds under management have an investment strategy that integrates sustainability risks into the investment process for that fund and that the delegated managers understand and explain how these risks may impact fund returns. In the circumstance that an appointed Investment Manager is not with scope for SFDR and elects not to implement a Sustainability Risk policy , appropriate disclosures will be made in the offering documents for that Fund. When undertaking the due diligence process on all appointed investment managers, Three Rock Capital Management will ensure that the appointees have the necessary expertise and resources to ensure that sustainability risks are embedded within their investment process and their risk management framework. Furthermore the Policy ensures that Three Rock Capital Management maintains the appropriate skills and resources to implement the requirements. A copy of the policy is available on request.
Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Remuneration Disclosure – Three Rock Capital Management Limited in complying with Article 5 of Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it has reviewed its Remuneration policy and that the policy incorporates provisions to ensure that it is aligned with Sustainable Finance Disclosure Regulation requirements. The policy incorporates the integration of risk management techniques to regulate individual behaviours with ESG factors.
Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Sustainability Due Diligence Disclosure – Three Rock Capital Management Limited in complying with Article 4 of Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it is not currently implementing a Sustainability Due Diligence Policy to measure the principal adverse impacts of investment decisions on Sustainability Factors ( as defined in SFDR). This decision has been reached to reflect the fact that the Three Rock Capital Management does not currently manage a significant number of Article 8 or Article 9 Funds (ESG Funds) under management. It is felt that until such a time that Three Rock Capital Management had a material number of ESG Funds on its platform, that the investor value derived from the provision of aggregate information on principal adverse impacts of the investment decisions on sustainability factors would not be material. Three Rock Capital Management will continue to monitor and periodically review this issue at Board level.
Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Management of ESG Funds Disclosure – Three Rock Capital Management Limited in complying with Article 10 of Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it is currently managing an Article 8 or Article 9 ESG Fund.
Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Marketing Communication Disclosure – Three Rock Capital Management Limited in complying with Article 13 of Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it is not making any claims in marketing materials or communications that are not aligned to the requirements of the Firm or its Funds under the regulation.
Three Rock Capital Management Limited – Sustainability Due Diligence / No consideration of sustainability adverse impacts – Taking due account, of the nature and scale of its activities and the range of Funds under management, Three Rock Capital Management Limited, in accordance with Article 4(1)(b) of the SFDR, has elected for the time being not to consider (in the manner specifically contemplated by Article 4(1)(a) of the SFDR) the principal adverse impacts of investment decisions of the Funds on Sustainability Factors. Manager considers this a pragmatic and economical approach to compliance with its obligations under the SFDR. The Firm may in the future look to consider the principal adverse impacts of investment decisions on sustainability factors within the meaning of Article 4(1)(a) of the SFDR, if the Manager considers that the results of such an assessment would prove meaningful to investors in the financial products it makes available.
| Artemis US Extended Alpha | Artemis Investment Management LLP | Artemis – Stewardship and ESG | Artemis Fund Managers (artemisfunds.com) |
| Allianz All China Equity | Allianz Global Investors GmbH | Allianz – Allianz Global Investors | ESG (allianzgi.com) |
| T. Rowe Price Asian Equity (ex-Japan) | T. Rowe Price International Ltd | TRP – Environmental, Social and Governance | T. Rowe Price |
| JP Morgan Emerging Markets Opportunities | JP Morgan Asset Management (UK) Limited | JPM – (jpmorgan.com) |
| Polar Capital Future Healthcare | Polar Capital LLP | Stewardship & ESG | Polar Capital (polarcapitalfunds.com) |
| Jupiter Strategic Absolute Return Bond Fund | Jupiter Investment Management Limited | Jupiter Asset Management – Board and Governance |
| Brandywine Global Income | Brandywine Global Investment Management LLC | Brandywine Global |
| Polar Capital Future Energy | Polar Capital LLP | Stewardship & ESG | Polar Capital (polarcapitalfunds.com) |
| Julius Baer Global Balanced GBP | Julius Baer International Limited | Our approach to sustainability (juliusbaer.com) |
| Flexible Strategy | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Dendro Fund | Bank Julius Bär & Co. AG | Our approach to sustainability (juliusbaer.com) |
| BlackRock Future Technology | Blackrock Financial Management Inc. | Our 2021 sustainability update | BlackRock |
| Julius Baer Fixed Maturity 2026 Asia | Bank Julius Baer & Co. AG, Singapore | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Equity Asia Income | Bank Julius Baer & Co. AG, Singapore | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Fixed Income Investment Grade Corporate (GBP) | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Columbia Threadneedle Future Environment | Columbia Threadneedle Management Limited | Responsible Investment |
| Julius Baer Global Growth GBP | Julius Baer International Limited | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Global Income Opportunities | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Dynamic Asset Allocation | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Equity Asia | Bank Julius Baer & Co. AG, Singapore | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Equity Global Excellence North America | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Fixed Income Asia | Bank Julius Baer & Co. AG, Singapore | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Fixed Income Investment Grade Corporate (EUR) | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Strategy Balanced (CHF) | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Strategy Balanced (EUR) | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Strategy Balanced (USD) | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Strategy Income (CHF) | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Strategy Income (USD) | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Asia REITs | Bank Julius Baer & Co. AG, Singapore | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Equity India | Bank Julius Baer & Co. AG, Singapore | Our approach to sustainability (juliusbaer.com) |
| JP Morgan Japan Equity Core | JP Morgan Asset Management (UK) Limited | JPM – (jpmorgan.com) |
| abrdn Emerging Markets Corporate Bond | abrdn Investments Limited | abrdn – Sustainable investing: our approach |
| Julius Baer Equity Global Excellence Mid Cap | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |
| Julius Baer Edelweiss Swiss Equity | Bank Julius Baer & Co. Ltd. | Our approach to sustainability (juliusbaer.com) |