QUAN Investors (“QUAN”) is committed to invest capital in a responsible manner. Where QUAN manages funds that qualify as Alternative Investment Funds (“AIF”) under the AIFMD, its primary responsibility is to act in accordance with the investment policy and framework of the AIFMD registration regime. QUAN bases its decision making in the interest of each of those Funds and their investors.
Sustainability related disclosures
In terms of the Sustainability Financial disclosure regulation (EU) 2019/2088 (SFDR), imposed by the EU, effective from 10 March 2021, QUAN as fund manager of two AIFM licensed funds (“the Funds”) is required to disclose information on how sustainability risks and considerations are integrated in the investment decision processes. The SFDR is part of broader efforts initiated by the European Commission to stimulate sustainable finance.
Regulatory status AIFMD
QUAN manages Alternative Investment Funds registered with the AFM and makes use of the exemption from the licensing requirement, as referred to in Section 2:66a of the Financial Supervision Act (the so-called AIFMD light regime).
ESG initiatives and disclosures
QUAN recognizes that exemplary Environmental, Social and Governance (ESG) performance will enhance the returns from investments. In addition, it could have an adverse effect on the value of the investment if not taken into account in the right way. Therefore, QUAN takes ESG risks into account when evaluating all its investment opportunities. Analysing these risks is therefore part of QUAN’s acquisition and due diligence procedure.
Material risks identified will be disclosed to (potential) investors in the information that is shared with them prior to investing in a specific investment fund (i.e. the information memorandum related to that specific investment).
No Principal Adverse Sustainability Impacts (“PAI”) statement
QUAN has analysed the nature and scale of its registered activities and the range of investments, and has concluded that it does not specifically consider the adverse effects of investment decisions on the so-called “sustainability factors” as referred to in Article 4 paragraph (1)(a) of the SFDR. Therefore the Funds that QUAN manages under the AIFMD registration regime do not annually publish a so-called “principal adverse sustainability impact statement” (hereinafter: “PAI statement”). The statements below endorse this decision;
- The investors in the Funds aim to preserve or grow capital and do not demand a PAI statement (yet).
- To be able to publish a PAI statement there are several requirements to be fulfilled. Measures should therefore be taken to be able to draft and publish a statement and to comply with the obligations arising from it. The potential added value for the investors in the Fund of issuing a PAI statement is disproportionate to the costs and time involved in drafting and maintaining that PAI statement.
QUAN (as fund manager) will reconsider the above if circumstances change in such a way that it is deemed necessary to review this decision. If the decision is reconsidered, QUAN (as fund manager) will inform the investors in the Funds.
Integration of sustainability risks in the remuneration policy
When awarding variable renumeration to employees, the variable renumeration will be based on the performance criteria for individual employees.
Variable renumeration is discretionary and dependent on the performance of the individual, the individual’s function profile, the AIFs, and the overall results of QUAN.