Sustainability-Related Disclosures (SFDR Article 3, Article 4 – Article 6 )
Clearflow Capital Management does not integrate sustainability risks systematically into investment decisions for the Fund and does not assess the adverse impact of such risks on expected returns for its investors.
The Fund is classified as an Article 6 product under the Sustainable Finance Disclosure Regulation (SFDR); it does not promote environmental or social characteristics and does not have a sustainable investment objective.
This Article 3 website policy on sustainability risks is published in the Sustainability/SFDR section will be reviewed periodically; the website will be updated if practices change.
In accordance with Article 4 SFDR, principal adverse impacts (PAIs) are not currently considered at entity level due to the size and nature of operations and limitations in data availability; this position is reviewed at least annually and will be updated should it change.
In line with certain international conventions and guidelines (including the UN Global Compact, OECD Guidelines for Multinational Enterprises, the United Nations Guiding Principles on Business and Human Rights, the Ottawa Convention, and the Convention on Cluster Munitions), Clearflow Capital Management avoids or limits investment in sectors or companies whose activities are contrary to these standards; this does not constitute an ESG investment strategy or the promotion of ESG characteristics.
The investments underlying the Fund do not take into account the EU criteria for environmentally sustainable economic activities.
For avoidance of doubt, the Fund may take short positions in companies or sectors excluded under the Fund’s ESG exclusion criteria specifically to express a negative view of their environmental, social, or governance practices. Any such activity will be disclosed in the Fund’s annual reports and documentation.