The below disclosures are applicable to EMK Capital Management Limited (“EMK”), a Jersey-based alternative investment fund manager advised by EMK Capital LLP. EMK is subject to certain regulatory disclosure and reporting requirements arising under the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (“SFDR”).  Certain SFDR disclosures are set out below.  For further SFDR related information and disclosures please contact EMK.

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Article 3 - Integration of sustainability risks into investment decision-making process.

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For the purposes of the below disclosure “Sustainability Risks” are environmental, social, or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of an investment by the funds which are managed by EMK. “Sustainability Factors” are, as relevant, environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

EMK considers sustainability risks and factors during the investment process, as outlined in our Responsible Investment Policy (“Policy”). The Policy outlines EMK’s approach to the assessment and management of environmental, social and governance (“ESG”) issues during the investment process and outlines the approach taken to investing responsibly across funds managed by EMK.

The Policy sets out the principles applied by EMK to assess and manage sustainability risks when making an investment decision, and for ongoing management of the portfolio. Additional guidance, documents and tools are applied internally to support the investment teams in the application of the Policy. EMK assesses a prospective target company’s ESG risks and opportunities during the due diligence process. In situations where ESG risks or opportunities require further scrutiny, external specialists will be instructed to undertake detailed ESG due diligence or produce reports on a specialist topic area. Any material findings identified are analysed and presented to the Investment Committee in a dedicated ESG section in the relevant investment memorandum. If the risks identified during the due diligence process are too great and cannot be appropriately mitigated, EMK will not pursue the investment.

EMK’s Head of ESG & Impact is responsible for the implementation of the Policy.

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Article 4 – Principal Adverse Impacts (PAI) Disclosure

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EMK engages with portfolio companies to understand and monitor sustainability factors on a regular basis. However, EMK does not currently consider adverse impacts of investment decisions on sustainability factors as described in Article 4 of the SFDR in the manner prescribed by the accompanying regulatory technical standards as it is not yet required to do so under SFDR; however, EMK keeps this situation under ongoing review. Instead, EMK considers sustainability factors which are appropriate and material to the companies that the EMK managed funds invest in and uses its own procedures, policies and metrics to assess negative impacts of investment decisions on such sustainability factors. In addition, EMK also reports meaningful ESG data to its investors – including making data prescribed by the ESG Data Convergence Initiative’s (EDCI) KPIs available to its investors.

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Article 5 – Entity Level Remuneration Policy Disclosure

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EMK considers sustainability risks, alongside other risks, in its remuneration policies to ensure sound and effective risk management.  

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