Legal Disclosures

Sustainability Related Disclosures (firm-wide)

Disclosure pursuant to Article 3 SFDR (policies on the integration of sustainability risks)

In the scope of application of SFDR, “sustainability risk” means an event or condition of an environmental, social, or governance nature that, upon occurrence, could have a potential material impact on the value of an investment. Praesidium attributes particular importance to Environmental, Social and Governance (ESG) factors and introduces within its own framework of investment, risk, and operational policies, a systematic monitoring of potential ESG risks in its new investments.

Disclosure pursuant to Article 4 SFDR (consideration of principal adverse impacts)

As per the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector, financial market participants (including AFIMs) are required to disclose on their website how principal adverse impacts (“PAI”) are considered at entity level. Having carefully reviewed the requirements of the aforementioned regulation, Praesidium S.A. does not consider PAI of its investment decisions on sustainability factors for the following reasons:

• The regulation states that consideration of PAI at the entity level is meant to be applied for the complete Fund range. As stated in our Funds documentation, not all of them fall under article 8 or article 9 of the Regulation. Consequently, the AIFM is not in a position to certify that all Funds it offers consider or will consider PAI.
• The whole set of mandatory indicators published in the Level 2 RTS cannot be taken into account for the complete Fund range of the AIFM since the AIFM only invests in private markets, predominantly in the US, where the availability of such detailed data is very limited.

Notwithstanding the above, Praesidium S.A. will keep assessing the feasibility of considering the PAI at entity-level on a regular basis and the position of the AIFM in this regard might be revised in the future.

Disclosure pursuant to Article 5 SFDR (remuneration policy)

Praesidium’s wishes to disclose that its strong commitment to ESG is reflected in its remuneration policy. An individual’s compensation and rewards is based on a yearly appraisal, in which contribution to ESG commitments, whether at corporate level or at investment level, are strongly encouraged and duly reported. Employees who show strong commitment and support Praesidium’s ESG objectives may receive a higher overall performance rating and remuneration.