Disclosures

Sustainability-related disclosures

The EU Sustainable Finance Disclosure Regulation (Regulation 2019/2088) (SFDR) has applied since 10 March 2021. This regulation requires financial market participants, including alternative investment fund managers, to disclose certain sustainability-related information publicly on their websites. Relevant disclosures are set out below.

INTEGRATION OF SUSTAINABILITY RISKS (ARTICLE 3 SFDR)

As a responsible investor, the integration of sustainability risks in the investment process is a key component of constructing a resilient, long-term portfolio.

Based on the respective fund or mandate-specific investment strategy, sustainability risks are identified as part of the investment-related due diligence and considered in the investment decision-making or advisory process. For this purpose, Aquila Capital leverages in-house expertise and specialised service providers that consider local requirements and investment-specific characteristics. Depending on the underlying asset class, sustainability risks are systematically assessed and documented.

Material findings identified in the due diligence phase are then incorporated into the investment decision as part of the investment proposal. Therefore, the outcomes of the due diligence can have a direct influence on the investment decision and may, in severe cases, lead to a negative investment decision if sufficient risk mitigation measures cannot be implemented.

Following a positive investment decision, ongoing monitoring is carried out at both portfolio and investment levels, as appropriate, based on the materiality of sustainability-related issues. The aim of this monitoring is to actively manage and reduce sustainability risks throughout the investment lifecycle to minimise any negative effects on returns.

ADVERSE SUSTAINABILITY IMPACTS AT ENTITY LEVEL (ARTICLE 4 SFDR)

Across Aquila Capital’s investment portfolio, the availability of sustainability data at entity level is limited . Therefore, in accordance with Article 4 SFDR, Principal Adverse Impacts at entity level are not considered at this stage. This decision will be reviewed regularly with regard to regulatory requirements and data availability.

INTEGRATION OF SUSTAINABILITY RISKS IN REMUNERATION POLICIES (ARTICLE 5 SFDR)

Aquila Capital's Remuneration Policy is consistent with the integration of sustainability risks; the policy is intended to avoid inappropriate environmental, social and governance sustainability risks. To this effect, each employee must comply with Aquila Capital’s ESG Integration Policy.

ADVERSE SUSTAINABILITY IMPACTS AT PRODUCT LEVEL (ARTICLE 7 SFDR)

Aquila Capital manages various funds for institutional and retail investors. For a portion of these funds, the adverse impacts of investment decisions on sustainability factors, also called Principal Adverse Impacts, are considered at product level in accordance with Article 7 SFDR. Please refer to the relevant product-specific SFDR disclosures for further information.

PRODUCT-LEVEL WEBSITE DISCLOSURES (ARTICLE 10 SFDR)

The product-level website disclosures under Article 10 SFDR can be found at the following link.

See our Glossary for definitions of key terms used on this page.

Our disclosures 
As of: 9.7.2026

Version history

9.6.2021: Initial publication of sustainability-related disclosures

27.7.2024: Additional remark on integration of ESG factors in the Remuneration Policy

31.7.2025: Update entity name to Aquila Capital

9.7.2026 Update ESG investment process and text