Sustainability-related disclosures

Sustainability risks disclosures (in accordance with Article 3 (1) of the SFDR) and disclosures related to the integration of sustainability risks in remuneration policy (in accordance with Article 5 (1) of the SFDR) are integrated in Stafford’s Responsible Investment Policy which is available here.



No consideration of adverse impacts of investment decisions on sustainability factors

Stafford Capital Partners (“Stafford”) is required to publish information on whether it considers the adverse impacts of investment decisions on sustainability factors (the “PAIs”) under the Regulation (EU) 2019/2088 (SFDR). Stafford does not currently consider the PAIs of investment decisions on sustainability factors in connection with its products and services, as defined under the Regulation (EU) 2019/2088. As an investor in third-party funds, Stafford depends on external managers to provide the relevant data on PAI indicators applicable to their investee companies as proposed by the draft regulatory technical standards. This is because, for as long as external managers are not reporting data on the GHG emissions, biodiversity impacts, social and employee matters and other impacts of their portfolio companies, Stafford is not, in its view, in a position to obtain and/or assess all the data which it would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost.

Stafford intends to keep the consideration of PAIs under review in the short to medium term.