Policy of Responsible Investment

Sustainability

Policy of Responsible Investment

In keeping with the Firm’s investment philosophy of navigating alpha-generating investment opportunities while dynamically managing risks, Chenavari recognises the importance of sustainability, namely Environmental, Social and Governance (“ESG”) considerations for its investment decisions and active ownership practices.

ESG matters can both drive financial out-performance and help identify risks which could negatively impact investments. As such, Chenavari is committed to integrating sustainability factors into its investment decision-making process.

Chenavari’s Policy of Responsible Investment is intended to set out basic principles and guidelines as well as to promote and enhance the Firm’s culture of responsible investing.

Chenavari's Policy of Responsible Investment is available at this link.

Negative Screening and Exclusions

Chenavari excludes certain sectors, issuers or securities for poor ESG performance based on specific ESG criteria, e.g. avoiding particular products/services or business practices.

Chenavari excludes companies whose principal business is directly derived from the production of or trade in controversial weapons (including anti-personnel landmines, cluster weapons, nuclear weapons, and chemical and biological weapons), or the manufacturing of tobacco products.

The Firm maintains absolute avoidance of companies which are known to be involved in the trade of products, services or activities involving pornography or prostitution, human trafficking, sexual violence against women, forced labour or child labour as defined by the International Labour Organisation (ILO) conventions, severe environmental damage, gross corruption, including extortion and bribery.

Chenavari also uses a materiality threshold (30%) based on revenues directly derived from thermal coal mining or the generation of electricity using coal. When applying the revenue threshold, attention will be paid to forward-looking plans from the entities in question to reduce their dependency on thermal coal operations over time.

For complex situations, the investment teams may refer to the ESG Committee, which deliberates on a case-by-case basis.

ESG Integration

In recent years, the industry has become more aware of methodologies for incorporating sustainability risks into investment research and decision-making. Chenavari acknowledges these developments and seeks to refine its process in this area.

As an example, the Lyxor / Chenavari Credit Fund portfolio managers are now able to apply their investment discretion in analysing issuers on both financial as well as non-financial characteristics, including ESG factors or criteria, to identify material risks or opportunities which may impair or enhance an issuer’s ability to service its debt obligations. We have contracted the services of a world leading ESG data provider to empower our portfolio managers with objective independent ESG research.

For private credit investments, we are developing policies and procedures to assist the pre-investment analysis as well as monitoring of relevant sustainability risks during the life of the investments.

EU Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (“SFDR”) aims to reduce information asymmetries in principal‐agent relationships with regard to the integration of sustainability risks, the consideration of adverse sustainability impacts, the promotion of environmental or social characteristics, and sustainable investment, by requiring financial market participants and financial advisers to make pre‐contractual and ongoing disclosures to end investors when they act as agents of those end investors (principals).

Chenavari's Policy for Reponsible Investment discloses specific information regarding our approaches to the integration of sustainability risks. Please follow this link for more information about the Firm's consideration of adverse sustainability impacts as well as transparency about remuneration policies in relation to the integration of sustainability risks.

Disclaimer

All persons using the www.chenavari.com (“Chenavari Website”) expressly agree to the foregoing disclaimer as a pre-condition to using the Chenavari Website for any purpose whatsoever. The Chenavari Website gathers information about Chenavari Financial Group and Chenavari Credit Partners LLP (the “Chenavari Companies”). The Chenavari Website has been provided for information purposes only and may not be relied upon by you in evaluating the merits of investing in any securities or interests referred to on this website. This website is not for retail investors and is directed only at investment professionals as defined in Article 19(5) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 or qualified investors within the meaning of Article 2(1)(e) of the Prospectus Directive (“Qualified Investors”). For the purposes of this provision, the expression “Prospectus Directive” means Directive 2003/71/EC (as amended by Directive 2010/73/EU).

The Chenavari Companies may change these conditions, at any time, which will be posted accordingly on the Chenavari Website. Your access to the Chenavari Website is governed by the relevant conditions in place at the time of browsing. To the maximum extent permitted by law, the Chenavari Companies disclaim all liability to you arising out of your use of the Chenavari Website. All disputes relating to these conditions or your use of the Chenavari Website are governed by the laws of England and Wales. The Chenavari Website is intended solely for the use of eligible counterparties or professional clients, for the purposes of the UK Financial Conduct Authority’s rules, who can afford the risks inherent in the instruments offered or managed by Chenavari Companies. All persons subscribing for an investment must be able to bear the risks involved and must meet the suitability requirements relating to such investments.

The Chenavari Website is not intended as, and is not to be taken as an offer or solicitation with respect to the purchase or sale of any security or interest, nor does it constitute an offer or solicitation in any jurisdiction, including those in which such an offer or solicitation is not authorised to any person to whom it is unlawful to make such a solicitation or offer. None of the securities referred to in the website have been or will be registered under the US Securities Act of 1933 or the securities laws of any other jurisdiction, and may be offered and sold in the United States and elsewhere only in accordance with an applicable exemption from the registration requirements thereof. The funds have not been registered under the US Investment Company Act of 1940. Furthermore, Subject to certain exceptions, the securities referred to herein and on the pages that follow may not be offered, sold, resold, taken up, exercised, renounced, transferred, delivered or distributed, directly or indirectly, in Australia, Canada, or Japan or to any resident or citizen of Australia, Canada, or Japan. The offer and sale of the securities referred to herein and on the pages that follow have not been and will not be registered under the applicable securities laws of Australia, Canada, or Japan. or any other jurisdiction which would be prohibited by applicable law.

The following web pages contain information on foreign collective investment schemes which have not been approved by the Swiss Financial Market Supervisory Authority (FINMA) for distribution in or from Switzerland to non-qualified investors in accordance with Article 119 et seq of the Federal Act on Collective Investment Schemes of 23 June 2006 (“CISA”). The information contained in the following pages is only directed to “qualified investors” within the meaning of Article 10 CISA with domicile/registered seat in Switzerland.

By clicking on the “ACCEPT” button, you certify that you are a qualified investor, an institutional investor or a financial professional in your own Jurisdiction and that nothing prevents you from getting access to the information available on this website.

Whilst the information contained on the Chenavari Website has been given in good faith and every effort has been made to ensure its accuracy. The information and any opinions contained herein have been obtained from or are based on sources which are believed to be reliable. The Chenavari Companies expressly disclaim making any express or implied warranties with respect to the fitness of the information contained herein for any particular usage, its merchantability or its application or purpose. The Chenavari Website is not intended to constitute, and should not be construed as investment advice. Prior to making any investment or hiring any investment manager you should consult with a professional financial advisor, legal and tax advisor to assist in due diligence as may be appropriate and determining the appropriateness of the risk associated with a particular investment.

Furthermore, to the extent permitted by law, neither the funds managed by Chenavari Credit Partners LLP nor any of their agents, service providers or professional advisers assumes any liability or responsibility nor owes any duty of care for any consequences of any person acting or refraining to act in reliance on the information contained in the Chenavari Website or for any decision based on it. In particular, neither of the Chenavari Companies shall be liable for any direct or indirect loss or damage to you, any loss of profits, loss of business, revenue, data, goodwill or anticipated servicing, or any consequential loss or damage.

Any of the Chenavari Companies’ instruments should review the prospectus of the funds and strategies before making an investment decision and should rely only on the information contained in the instrument offering documentation. Past performance is not necessarily indicative of future results. The actual performance realised by any given investor will depend on, amongst other things, the Fund invested into, the class of shares/interests subscribed for the period during which such shares/interests are held and in what currency such shares/interests are held. Prospective investors should take appropriate advice, on the legal requirements, possible tax consequences, foreign exchange restrictions or exchange control requirements that they may encounter under the laws of the countries of their citizenship, residence or domicile and that may be relevant to the subscription, purchase, holding, exchange, redemption or disposal of any investments. Chenavari Companies reserve the right to terminate, at any time, any User’s account without giving notice or a reason for such termination to the User.

Users of the Chenavari Website may view, download and print information and materials for its personal and internal business use provided that all hard copies contain all copyright and other applicable notices; all content on the Chenavari Website is protected by copyright. All Users may not reproduce, modify, copy, alter in any way, distribute, sell, resell, transmit, transfer, license, assign or publish any information obtained from the Chenavari Website. Users shall not use this site at any time for any purpose that is unlawful or prohibited and shall comply with any applicable local, state, national or international laws or regulations when using the Chenavari Website. We are concerned about the privacy of any personal information you may provide to us through this Website.

Chenavari Companies, and the logos and marks included on the Chenavari Website that identify the Chenavari Companies’ services and products are proprietary materials. The use of such terms and logos and marks without the express written consent of Chenavari Companies is strictly prohibited. Copyright in the pages and in the screens of the Chenavari Website, and in the information and material therein, is proprietary material owned by Chenavari Companies unless otherwise indicated. The unauthorized use of any material on the Chenavari Website may violate numerous statutes, regulations and laws, including, but not limited to, copyright, trademark, trade secret or patent laws.

If any provision in this Disclaimer Agreement is held to be invalid or unenforceable, then the remaining provisions shall continue in full force and effect.

Telephone communications or conversations between an Investor and the Investment Manager, the AIFM or the Administrator will be recorded to the extent that that they result or may result in activities in financial instruments (as defined in MIFID II).