While ACAL Private Equity – SICAR SCA generally considers certain sustainability risks in its investment activity, it does not currently evaluate the principal adverse impacts (PAI) of investment decisions on a uniform set of sustainability factors within the meaning of Article 2(24) of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector, as amended (SFDR), with respect to all compartments of ACAL Private Equity – SICAR SCA, given the overall difficulties in collecting the necessary information for this purpose and the resources required to establish adequate processes.
In addition, the AIFM maintains a remuneration framework in line with applicable Luxembourg laws and regulations, including the requirements of the AIFMD and the SFDR. As an internal AIFM, the framework applies to members of the Board of Managers and staff whose professional activities have a material impact on the risk profile of the Fund. It is proportionate to the size and nature of the AIFM, reviewed on a regular basis, and consists primarily of fixed components reflecting responsibilities and experience.
Variable components, where applicable, are limited, discretionary, and structured to avoid incentives for excessive risk- taking.
In accordance with the SFDR, the remuneration framework also integrates sustainability risks by ensuring that no element of remuneration encourages a disregard of such risks.
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