Sephira Asset Management Fund S.C.A. SICAV-SIF (hereafter “Fund”) is an open-ended investment company organised as a partnership limited by shares (société en commandite par actions) under the laws of the Grand Duchy of Luxembourg and qualifies as a société d'investissement à capital variable – fonds d'investissement spécialisé (SICAV-SIF). The Fund is governed by:
The Fund is authorised by Commission de Surveillance du Secteur Financier in Luxembourg (CSSF) as an undertaking for collective investment (the UCI) with the General Partner, Sephira Asset Management S.à r.l. (hereafter “AIFM”), acting as the registered external AIFM of the Fund.
Both, the General Partner and the Fund, are fully compliant with all CSSF circulars and guidelines.
In addition, AIFM has adopted the CFA Institute Asset Manager Code of Professional Conduct for ethical and responsible asset management.
In order to ensure the transparency of its operations to investors, this section discloses key third-party service providers utilised by AIFM in the course of its business. AIFM conducts rigorous processes for selecting and monitoring third parties, consisting of initial due diligence, ongoing monitoring, and periodic risk assessment that have been integrated into the risk management processes of AIFM. The following list presents key third parties providing services for AIFM and the Fund.
Depositary
Q Securities S.A. Luxembourg Branch
46A, Avenue John F. Kennedy
L- 1855 Luxembourg
Grand Duchy of Luxembourg
Prime Broker
Interactive Brokers Ireland Limited
10 Earlsfort Terrace
Dublin, D02 T380
Ireland
Administrative & Transfer Agent
Bolder Luxembourg S.A.
7, rue Lou Hemmer
L-1748 Senningerberg
Grand Duchy of Luxembourg
Auditor
Artemis Audit & Advisory
25 A, Boulevard Royal
L-1736 Senningerberg
Grand Duchy of Luxembourg
AIFM treats the issues of customer privacy and its protection with utmost importance. This section setsout how the AIFM and its affiliates, agents, and representatives, process the personal data of externalstakeholders.
What type of information is being collected and why?
AIFM may collect your personal information in the following contexts:
How is the information collected?
AIFM may collect your personal data via different means including among others:
How is the information secured?
As a regulated financial entity in Luxembourg, AIFM is subject to organisational and technical measures to prevent loss, misuse, accidental or unauthorised disclosure or destruction, or access to your personal data. AIFM maintains the appropriate technical and organisational security measures to protect your personal data against loss, destruction, theft, misuse, unauthorised access, modification, or alteration.
How long will the information be retained?
Your personal data will be processed for only the minimum period which is necessary depending on the legal/regulatory requirements for which the data was obtained and should be retained.
Whom will the information be shared with?
AIFM may disclose your personal data to its auditor, other relevant service providers (Administrative & Transfer Agent, Registrar, Fund Accountant), or to the competent authorities (CSSF, Luxembourg Tax Authorities, Luxembourg Court, or other applicable bodies) in the contexts described above. Such disclosure will be done in accordance with the applicable laws and regulations. Please note that the disclosure of personal information as set out in the above paragraph may involve the transfer of data to other jurisdictions outside the European Economic Area (EEA). Such countries may not have the same data protection laws as your jurisdiction. In any case, AIFM will transfer your personal data based on adequacy decisions, suitable standard contractual clauses as approved by the European Union Commission, or other valid transfer mechanisms.
The EU regulation on data protection (GDPR) safeguards your rights regarding your privacy and personal information which include the right to:
Should you wish to exercise the above rights, AIFM will answer your request regarding your personal information as soon as it is possible and within a reasonable delay after receipt of your demand. Please note that the exercise of the above rights is subject to certain conditions and in particular to legal obligations such as the minimum retention period which AIFM must comply with.
For any questions about topics related to your personal data, your rights, and their application, you can contact AIFM via email or post. You may also file a complaint about any presumed misconduct, breach, or unauthorized disclosure that may have occurred by our treatment of your personal information within the application of privacy laws and regulations. In addition, you have the right to lodge a complaint with the supervisory authority managing privacy matters.
The herein information is published pursuant to Articles 3(1), 4, and 5(1) of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures (SFDR) in the financial services sector.
The Regulation (EU) 2019/2088 on SFDR is a pillar of the EU sustainable finance agenda. SFDR aims to increase the transparency of financial market participants toward end investors and contribute to the objective of fighting greenwashing. The SFDR focuses on the environmental and social impact of an entity’s investment decision.
Based on SFDR, AIFM is classified as a “financial market participant”, and in accordance with Articles 3(1), 4, and 5(1) of SFDR, has to perform the following SFRD disclosures:
Integration of sustainability risks
AIFM has integrated sustainability risks into its risk management framework and introduced the consideration of sustainability risk in the investment decision-making process for the Fund under management.
Following Art. 2 (22) of the SFDR sustainability risk has been defined in AIFM’s policies as “an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment.” The possible materialization of sustainability risk is analyzed during the due diligence phase of the investment decision-making process, and the monitoring and measurement of that risk is an integral element of regular processes conducted by the Risk Management Function of AIFM. The outcome of such analyses is summarized in the periodic risk reports prepared for the Fund.
No consideration of adverse impacts of investment decisions on sustainability factors
Under SFDR “principal adverse impact of investment decisions on sustainability factors” (PAI) are impacts of investment decisions that result in negative effects on sustainability factors (i.e. environmental, social, and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters).
Currently, AIFM does not consider adverse impacts of investment decisions on sustainability factors, consistent with the provisions of Article 4(1)(b) of the SFDR. The decision to opt out of such consideration is motivated by an absence of data (both quantity and quality) to perform a meaningful assessment of the potential adverse impact of the investment decisions on sustainability factors. In our opinion, the negative externalities caused by investment decisions undertaken by AIFM cannot be effectively measured based on a limited level of relevant disclosure in the financial market and short history of available sustainability factors data.
AIFM will closely monitor the evolving market practices and any material amendment to the above approach will be updated on the website in accordance with the SFDR.
Transparency of the remuneration policy in relation to the integration of the sustainability risks
AIFM ensures that its remuneration policy is consistent with the integration of sustainability risks. Notably, AIFM ascertains that when determining the variable remuneration of its identified staff, the Board of Managers of AIFM takes into account the compliance of the relevant staff member with all procedures and policies of the company, including those relating to the integration of sustainability risks.
The remuneration policy promotes sound and effective risk management with respect to sustainability risks whereas the structure of remuneration will not encourage excessive risk‐taking with respect to sustainability risks. According to the remuneration policy, the structure of remuneration does not encourage excessive risk-taking with respect to direct or indirect sustainability risks.
Last modified on 10/10/2022