The purpose of this document is to outline the approach of AUDENTIA CAPITAL MANAGEMENT LIMITED (the “Company”) to responsible investment, which is broadly defined as a strategy to incorporate environmental, social and governance factors in investment decisions. This Sustainability Risk Policy (hereinafter the “Sustainability Risk Policy”) is built on Company’s commitment to sustainable investment practices.

This policy has been adopted in accordance with the provisions of 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 (“SFDR”).

The Board will periodically review this document to ensure that it remains up-to-date and consistent with the Company’s regulatory obligations under applicable law and risk appetite. The Board shall be responsible for initiating and facilitating an annual review of this document and itsimplementation, which review shall be carried out in light of legal and business developments as well as the Company’s experiences in its implementation.

All changes or material exceptions to this document are to be approved by the Board, whether in relation to the annual review or otherwise.


The Company is an Alternative Investment Fund Manager licensed by the Malta Financial Services Authority.

The Company falls within scope of the Sustainable Finance Disclosure Regulation requiring financial market participants, including the Company, to make certain pre-contractual and ongoing disclosures to end investors. In line with the requirements under said regulation, the Company has formulated this Sustainability Risk Policy outlining the approach that the Company takes to integrating environmental, social and governance (“ESG”) considerations into its investment management processes by assessing not only all relevant financial risks but also relevant sustainability risks, with a view to mitigating risks and enhancing returns over the medium to long-term.

The Company is also required to publish on its website information about its policies on the integration of sustainability risks in its investment decision‐making process. SFDR defines ‘sustainability risk’ as an “environmental, social or governance event or condition that, if it occurs,
could cause an actual or a potential material negative impact on the value of the investment” (the “Sustainability Risk”).

The Company is also required to include in its remuneration policies information on how these policies are consistent with the integration of Sustainability Risks and to include a description of the following matters in its pre‐contractual disclosures:

  • a) the manner in which sustainability risks are integrated into their investment decisions
  • b) the results of the assessment of the likely impacts of sustainability risks on the returns of the financial products they make available.


In this Sustainability Risk Policy, the following terms, when used, shall have the meanings set out hereunder:

Principal adverse impacts means those impacts of investment decisions that result in negative effects on sustainability factors (as defined below)
Sustainability factors shall have the meaning assigned to it in the SFDR (as defined below), this being “environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters;”
Sustainability risk shall have the meaning assigned to it in the SFDR (as defined below), this being “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment”; and
SFDR or the Sustainable Finance Disclosure Regulation means 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.
SFDR RTS Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying the details of the content and presentation of the information in relation to the principle of ‘do no significant harm’, specifying the content, methodologies and presentation of information in relation to sustainability indicators and adverse sustainability impacts, and the content and presentation of the information in relation to the promotion of environmental or social characteristics and sustainable investment objectives in pre-contractual documents, on websites and in periodic reports.
Taxonomy Regulation means Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088.

4. Outsourcing, Delegation and Appointment of Investment Advisors

In the event that the Company outsources or delegates to other third party managers and/or investment advisors (the “Delegates”), the performance of any of its functions, the Company shall ensure that the Delegates have in place an ESG policy or as a minimum adopt the Company’s ESG Policy

5. Products with a Sustainable Investment Objective

In general, the Funds managed by the Company do not take into account the adverse impacts of investment decisions on sustainability factors, as required by Article 4 (1) (b) of the SFDR. Notwithstanding the above when the Company manages funds Article 9 as per SFDR classification, the following shall be considered:

  1. a) Principal Adverse Impacts
    The Company undertakes an assessment of the principal adverse impacts (“PAIs”) of its investment decisions on Sustainability Factors. PAIs are those impacts arising from investment decisions that have a negative effect on Sustainability Factors. Where the PAI cannot possibly be determined due to insufficient disclosure or lack of tangible data, the Company will actively engage with the target company in question and should no commitment be made by the latter to mitigate the PAI, this matter will be factored into the decision-making process.

    The Company has disclosed on its website a statement on the due diligence process in respect identified PAI arising from the Company’s investment decisions.

  2. b) Responsible Investment Practices
    The Board is charged with the promotion of awareness and understanding of ESG considerations within the investment team and to integrate due consideration of Sustainability Factors and Sustainability Risks into their investment decision making process, engagement efforts and to share such knowledge with other employees of the Company.

    The Company seeks to understand and identify material Sustainability Factors that have investment ramifications, and which can have a material impact on the investment’s long-term financial performance. Sustainability Factors that are considered by the Company include, but are not limited to:

    • – Environmental: climate change; air/water pollution; biodiversity; deforestation; energy efficiency; carbon intensity; depletion of finite resources; and product evolution (energy-efficient products/renewable energy).
    • – Social: human rights; unethical supply chains; severe labour controversies; brand and reputational issues; and illegal working conditions.
    • – Governance: transparency & integrity; inadequate management of conflicts of interests; corporate governance failures; lack of appropriate board oversight; shareholder rights; bribery and corruption.

Information on Sustainability Factors is integrated in the Company’s investment decision making process for all asset classes that it deals in. While these matters are considered, it remains the case that Sustainability Factors are secondary in nature to the overall Investment Objective as elaborated in the respective Offering Documents of each of the Funds it manages.

The Company carries out an assessment and obtains information of Sustainability Factors in respect of the individual investments in which it invests. This is done with a view to ensuring that Sustainability Risk is identified and appropriately managed. The Company considers that sustainability risks are mitigated by the very nature of the positive ESG impact resulting from the successful employment of the investment objective as defined in the respective Offering Document of each of the Funds it manages.

Information on Sustainability Factors and related Sustainability Risks are incorporated into the Company’s investment decision-making processes at the asset selection stage when undertaking due diligence on such asset class and, where possible, assessed in terms of the potential financial impact in the long term. When undertaking the ESG analysis, the Company will seek to obtain information from a variety of sources, including, but not limited to:

  1. i. The target company itself;
  2. ii. third party specialist data providers;
  3. iii. brokers; and
  4. iv. Academics.

The Company will ordinarily also rely on due diligence measures adopted by target companies to identify, mitigate, and report on Sustainability Risk.

Sustainability Risks and/or opportunities vary by country, industry, markets, as well as by characteristics specific to a target company such as size and geographical footprint. These matters are taken into consideration when undertaking the assessment of the Sustainability Factors and Sustainability Risks associated with a target investment.

Inadequate management of Sustainability Risk can lead to inefficiencies, operational disruption, litigation, and reputational damage. These outcomes may impact the performance of the investment and ultimately the financial returns of the Company’s clients.

The integration of information on Sustainability Factors and Sustainability Risks into investment decision making processes enhances the Company’s understanding of sectors, assets and companies and their ability to deliver sustainable, long term shareholder value.

  • ESG integration

The Company integrates information on Sustainability Factors in its investment strategy, whereby Sustainability Risks are considered in the broader investment process and analyses across the asset classes and ultimately in the investment decisions undertaken by the Company.

When assessing a target company, the Company takes into account the extent to which the target company:

  1. i. embeds responsible business conduct not its policies;
  2. ii. identifies and assesses adverse impacts in operations, supply chains and business relationships;
  3. iii. prevents or mitigates adverse impacts on Sustainability Factors;
  4. iv. tracks and implements enhancements to its processes; and
  5. v. communicates how adverse impacts are assessed

In this respect, the Company assesses the extent to which the target companies follow the principles set out in the OECD Due Diligence Guidance for Responsible Business Conduct. The objective of the OECD Due Diligence Guidance for Responsible Business Conduct is to “…provide practical support to enterprises on the implementation of the OECD Guidelines for Multinational Enterprises by providing plain language explanations of its due diligence recommendations and associated provisions. Implementing these recommendations helps enterprises avoid and address adverse impacts related to workers, human rights, the environment, bribery, consumers and corporate governance that may be associated with their operations, supply chains and other business relationships….” .

The Company adopts a pragmatic approach whereby information on Sustainability factors is integrated into established investment assessment processes. The Company does not have a separate ESG focused processes. With investments spanning over various asset classes, jurisdictions, sectors, and markets, the Company takes into account legal and cultural differences in different markets. Thus, the ESG analysis is sensitive to the individual situation pertaining to each target company in terms of the local norms, laws, regulation, and expectations of the market in which it operates.

The Company does not automatically exclude investments in products/ target companies purely on ESG grounds if the Company, feels that such Sustainability Risks do not necessarily pose a financial risk in the long term. The purpose of integrating information on Sustainability Factors and related Sustainability Risks in the investment decision making process does not automatically exclude certain products/ target companies as the investment decision making process takes into consideration other factors and risk.

  • Screening

The Company could apply a set of filters for the purpose of determining which companies, sectors or activities are eligible or ineligible to be invested in based on its preferences, values and/or ethics.

Certain clients may have concerns about specific activities or industries and may instruct the Company to exclude such activities or industries. In the circumstances, the Company will actively engage with its clients to better understand and define these criteria such that it is able to maintain such exclusions on an on-going basis.

The Company also screens target companies/ products that promote and provide solutions that are consistent with Sustainability Factors and aims at including such products in the portfolios managed by the Company. The Company will also positively recommend such products on an on-going basis. Once invested in, the on-going eligibility of said companies, sectors or activities is likely to be revisited on a periodic basis or if there are significant changes.


The Company also considers the principle of ‘does no significant harm’. This principle considers an investment to be ‘sustainable’ if it contributes to an environmental or social objective and does not significantly harm any other environmental or social objective as set out in the Regulation.


Concerning the strategies discussed in this ESG Policy, the Company promotes one product which is specifically labelled as an ESG product, namely the Ecoener Inversiones Fund, designated under Article 9 of SFDR. Whilst an ESG integration strategy continues to be applied, it may not necessarily be the only emphasis of all products managed by the Company, particularly in the case of the other sub-funds managed by the Company designated under Article 6 of SFDR.


The responsibility of the enforcement of this Sustainability Risk Policy lies with the board of the Company which shall be accountable for achieving the commitments outlined herein.

This Sustainability Risk Policy was approved by the Board of Directors of the Company on 23rd November 2021. This Sustainability Risk Policy shall be reviewed at least once a year to measure success and determine whether it continues to reflect Company’s investment beliefs.