The information on this page describes 3xP Global approach to SFDR and includes our policies and procedures, disclosed in accordance with these new rules.
Integration of Sustainability Risks
Art. 3 of Regulation (EU) 2019/2088 - disclose the entity's guidelines for integration of sustainability risks into the investment process
Our Sustainability Policy
provides information about the integration of sustainability risks into our investment decision-making process.
Sustainability Risks include (but are not limited to) the following:
- Environmental risks such as the impact of environmental events such as increased flooding risks on operations of portfolio companies;
- Social risks such as impact of non-compliance with anti-slavery or working conditions laws and regulations by portfolio companies; and
- Governance risks such as inadequate management oversight of portfolio companies.No consideration of principal adverse sustainability impacts
Art. 4 of Regulation (EU) 2019/2088, disclose whether principal adverse impacts of investment decisions or advice on sustainability factors are considered as part of the investment decision or advice
We are also actively working on internal frameworks that will lead to the collection and quantification of data, and reporting on the Principal Adverse Impacts of investment decisions on sustainability factors before the regulatory technical standards come into effect, which is expected to occur on 2023.
3xP Global is mindful of the importance of considering the Principal Adverse Impacts of investment decisions on sustainability factors.
3xP Global is implementing the required processes and tools to obtain and measure the data required by SFDR to report Principal Adverse Impacts of investment decisions on sustainability factors.
We are working to quantify and report upon the principal adverse impacts of investment decisions on sustainability factors before the regulatory technical standards coming into effect, which is expected to occur on January 2023.Remuneration and integration of sustainability risks
Art. 5 of Regulation (EU) 2019/2088, disclose how remuneration principles relate to the integration of sustainability risks disclosed under art. 3 of the SFDR.
Our remuneration policy is consistent with the integration of Sustainability Risks both in the long term and with respect to more short-term variable compensation.
Remuneration is generally provided on a fixed basis and may include participation in the firm’s annual performance, which considers both financial criteria and firm’s external validation of its ESG policy. This involves the attribution and maintenance of certifications, like B Corp, and awards related to its direct activity, like EVCA awards and other. All criteria are revised on a regular basis.
3xP Global receives a mandate by every single investor to manage her or his savings based on strict criteria of prudence and informed decisions. Remuneration policy also considers the contribution to effective risk management both company and its portfolios. Our risk management approach considers financial risks, regulatory, security and fraud, operational risks, with special attention to the impacts on the environment and all stakeholders.
3xP Global’s Grow Sustainable Program aims to raise awareness about sustainable practices on our ecosystem and on corporate world. Employees’ alignment with this program is taken into consideration on regular performance review, having a potential positive impact on individual remuneration. All staff has a combination of fixed and variable remuneration where the performance of the Funds does not directly impact the remuneration of the remuneration.
Considering the limited impact of the variable remuneration on the risk profile of the funds and the nature of the business of 3xP Global, we believe remuneration components are not based on the performance of the Funds and that there is no risk of misalignment with the sustainability risks associated with the investment decision making process of the Company in respect of the Funds.SFDR Product Categorisation
Art. 10 of Regulation (EU) 2019/2088, Transparency of the promotion of environmental or social characteristics and of sustainable investments on websites
So far, all products managed by 3xP Global that fall within the scope of SFDR meet the conditions set out in Article 6 of SFDR as sustainability risks are integrated into the investment decision making process. However, we are making the necessary adjustments to classify our products as Article 8 or 9 funds, under the SFDR requirements.