Sustainability-related Disclosures


Sustainable Finance Disclosure Regulation (SFDR) Entity-level Disclosure

Renaissance AIFM S.à r.l (hereinafter “Renaissance”, the “AIFM” or the “Company”) is an alternative investment fund manager based in Luxembourg and regulated by the Commission de Surveillance du Secteur Financier (CSSF). The Company is subject to the Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (the “SFDR”) and provides disclosures in compliance with Articles 3(1), 4(1)(b), and 5(1) of the Regulation as follows.

Sustainability risk policies

Renaissance recognizes that the integration of sustainability risks into the investment decision-making process is a critical component of long-term value creation and sound risk management. Sustainability risks — defined as any 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 an investment— are systematically considered across all investment strategies managed by the AIFM.

The integration of sustainability risks is guided by Renaissance’s overarching Sustainability Policy and further articulated in the respective responsible investment policies, which outline strategy-specific ESG considerations. These policies serve as the foundation for embedding financially material ESG factors into investment screening, due diligence, decision-making, and ownership practices.

Renaissance embraces sustainable practices, believing that embedding financially material ESG factors supports the resilience of portfolios, helping to mitigate downside risks and enhance value creation opportunities. The AIFM’s ESG team works in close collaboration with investment teams to ensure that sustainability risks and opportunities are appropriately identified, assessed, and addressed within each investment strategy.

For more information, please refer to the Renaissance AIFM Sustainability Policy and Renaissance Partners Responsible Investment Policy.

No consideration of adverse impacts of investment decisions on sustainability factors

Renaissance does not currently consider or report on principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors at the entity level, as defined by the SFDR. This decision was made after careful assessment, due to ongoing limitations in data quality, consistency, and reliability across the investment universe.

In particular, Renaissance does not consider PAIs at entity level at the time being due to the operational complexity of applying a uniform set of sustainability indicators across a broad range of diversified investment strategies. The heterogeneity of investment strategies within Renaissance’s portfolios makes it challenging to ensure consistent, comparable, and reliable ESG-related data from all investee companies. In addition, the number of diversified investment strategies across Renaissance’s fund range entails that, although some financial products disclosing under Article 8 and Article 9 SFDR do consider PAIs at their own level, not all managed products take PAIs into account.

On a best-effort basis, Renaissance commits to reporting PAIs for selected investee companies where data is available, reliable, and of sufficient quality and granularity to ensure meaningful disclosure.

Renaissance integrates the consideration of PAIs in the investment decision making process for selected investment funds launched after the effective date of the SFDR and/or currently in their active investment period. For other funds, PAIs consideration may be applied on a more limited or best-effort basis, reflecting data availability and proportionality considerations.

The AIFM continues to monitor the evolving regulatory landscape and improvements in data consistency and quality. This position may be revisited in the future.

Remuneration policies in relation to the integration of sustainability risks

Renaissance has a remuneration policy that is consistent with the integration of sustainability risks. It is fully in line with our broader Sustainability Policy and aligns our employees' interests with the firm's long-term success and value creation for our investors. Our remuneration policy is designed to promote sound and effective risk management, including sustainability risks, and does not encourage excessive risk-taking with respect to sustainability.

When determining variable remuneration, Renaissance AIFM takes into account both financial and non-financial performance indicators. Among the non-financial indicators, ESG-related objectives may be considered — particularly the alignment of individual behavior with the firm’s sustainability goals (primarily reflected in its funds’ sustainability objectives) and adherence to ESG risk management principles. These factors are assessed as part of the overall performance evaluation. The level of achievement of ESG objectives is considered when calculating variable remuneration, based on each professional’s specific role, responsibilities and scope of influence. This ensures that the incentives provided to our staff are aligned with our commitment to identifying, assessing, and managing sustainability risks in our investment processes and strategies. The remuneration policy supports our broader efforts to embed financially material ESG factors in asset management activities, thereby helping to mitigate downside risks and enhance value creation opportunities over the long term.

Sustainable Finance Disclosure Regulation (SFDR) Product-level Disclosure

During the fundraising period, the Article 10 website disclosures of the funds will be available in the data room that can be accessed by prospective investors through the following link, with login credentials that will be made available by the AIFM.
After the fundraising period and throughout the life of the funds, the Article 10 website disclosures of each fund will be available in the dedicated investor portal that can be accessed through the following link. For each investor, login credentials will be made available by the AIFM.

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