SFDR
Sustainable Finance Disclosure Regulation
Overview
Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”) requires financial market participants to make certain disclosures regarding the integration of sustainability risks and the consideration of adverse sustainability impacts in their investment processes.
Sustainability risk integration
33East LLC integrates sustainability risks into its investment decision-making process. 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.
We assess sustainability risks as part of our broader due diligence process alongside financial, legal, and operational considerations. At the early stage of investment, many portfolio companies are in the early stages of developing formal ESG frameworks, and our assessment reflects the nature of the companies in which we invest.
Principal adverse impacts
33East LLC does not currently consider the principal adverse impacts of investment decisions on sustainability factors as defined under SFDR. This reflects our current stage of development and the nature of our investment activity. We will continue to monitor regulatory developments and review this position as our firm and portfolio evolve.
Remuneration policy
33East LLC’s remuneration policy is consistent with the integration of sustainability risks. Our compensation structures are designed to ensure alignment between investment professionals and the long-term performance of our investments, which includes consideration of sustainability-related risks where relevant.
No sustainable investment objective
The financial products managed by 33East LLC do not have sustainable investment as their objective and do not promote environmental or social characteristics within the meaning of Articles 8 or 9 of SFDR. These products fall within the scope of Article 6 of SFDR.