Sustainability Risk Policy
In accordance with Article 3 of the SFDR EJF Capital Limited (“EJF”) recognises that sustainability risks can have an impact on the performance of assets, therefore as part of EJF’s fiduciary responsibility with regards to the products managed by EJF we are committed to more formally recognise sustainability risks within the investment due diligence process.
EJF’s approach to addressing Environmental, Social and Governance (“ESG”) criteria is evolving. EJF is committed to including ESG considerations in its investment process more broadly to account for sustainability risks. In November 2020, EJF formed an ESG Committee to more formally initiate the process of reviewing how we can develop and implement ESG factors into EJF’s investment analyses and processes. EJF will look to use ESG (sustainability) considerations as a risk management tool that can be used to analyse the underlying fundamentals of an investment and identify risk within existing investments. Our goal is to merge and integrate these considerations across asset classes and investments. For the purpose of SFDR, the sub-fund does not promote environmental or social characteristics or have sustainable investment objectives.
Principal Adverse Impacts
In accordance with Article 4 of the SFDR EJF Capital Limited (“EJF”) from 1 January 2022 will provide guidance about how principal adverse impacts of investment decisions on sustainability factors are taken into account within the investment due diligence process. If these factors are not considered in the investment due diligence process at this date clear reasons will be provided.
Currently EJF does not consider the principal adverse impacts of investment decisions on sustainability factors. This is due to the lack of consistent data in respect of ESG factors on the investments made by EJF to support this analysis. EJF’s approach to addressing Environmental, Social and Governance (“ESG”) criteria is evolving. EJF is committed to including ESG considerations in its investment process more broadly to account for sustainability risks. EJF is seeing increasing ESG information reporting from issuers and inclusion of ESG data by credit rating agencies and research providers that form a part of EJF’s investment due diligence process. Our goal is to integrate these considerations across asset classes and investments.
Remuneration Policies
In accordance with Article 5 of the of the SFDR EJF Capital LLC (“EJF”) integrates sustainability risks in the remuneration calculations for investment personnel. EJF recognises that sustainability risks can have an impact on the performance of assets. The performance of assets is one of the direct inputs into the remuneration calculations at EJF. Sustainability risks are also directly linked to remuneration for investment personnel.