Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Sustainability Risk Disclosure  –  Three Rock Capital Management Limited in complying with   Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it has implemented a Sustainability Risk Policy. This Policy ensures that all Funds under management have an investment strategy that integrates sustainability risks into the investment process for that fund and that the delegated managers understand and explain how these risks may impact fund returns. In the circumstance that an appointed Investment Manager is not with scope for SFDR and elects not to implement a Sustainability Risk policy , appropriate disclosures will be made in the offering documents for that Fund. When undertaking the due diligence process on all appointed investment managers, Three Rock Capital Management will ensure that the appointees have the necessary expertise and resources to ensure that sustainability risks are embedded within their investment process and their risk management framework. Furthermore the Policy ensures that Three Rock Capital Management maintains the appropriate skills and resources to implement the requirements. A copy of the policy is available on request.

 

Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Remuneration  Disclosure  – Three Rock Capital Management Limited in complying with Article 5 of  Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it has reviewed its Remuneration policy and that the policy incorporates provisions to ensure that it is aligned with Sustainable Finance Disclosure Regulation requirements. The policy incorporates the integration of risk management techniques to regulate individual behaviours with ESG factors.

 

Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Sustainability Due Diligence  Disclosure  – Three Rock Capital Management Limited in complying with  Article 4 of  Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it is not currently implementing a Sustainability Due Diligence Policy to measure the principal adverse impacts of investment decisions on Sustainability Factors ( as defined in SFDR). This decision has been reached to reflect the fact that the Three Rock Capital Management does not currently have any Article 8 or Article 9 Funds (ESG Funds) under management. It is felt that until such a time that Three Rock Capital Management had a material number of ESG Funds on its platform, that the investor value derived from the provision of aggregate information on principal adverse impacts of the investment decisions on sustainability factors would not be material. Three Rock Capital Management will continue to monitor and periodically review this issue at Board level.

 

Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Management of ESG Funds  Disclosure  – Three Rock Capital Management Limited in complying with  Article 10 of Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it is not currently managing any Article 8 or Article 9 ESG Funds.

 

Three Rock Capital Management Limited – Sustainable Finance Disclosure Regulation – Marketing Communication Disclosure  – Three Rock Capital Management Limited in complying with  Article 13 of Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation) confirms that it is not making any claims in marketing materials or communications that are not aligned to the requirements of the Firm or its Funds under the regulation.

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