Sustainability risk policies –Article 3
Pursuant to Article 3 of the SFDR, Alpha is required to disclose the manner in which sustainability risks are integrated into the investment decision-making process.
No consideration of sustainability adverse impacts – Article 4
Alpha does not currently publish information on its consideration of the “adverse impacts of investment decisions on sustainability factors” in accordance with the EU Regulation on sustainability-related disclosures in the financial services sector (the “SFDR”). This is due to the present uncertainty as to the scope and extent of the information required. Alpha seeks to publish information on its consideration of the “adverse impacts of investment decisions on sustainability factors” in accordance with the SFDR, as the scope of information required to be disclosed becomes clearer.
However, Alpha considers the principal adverse impacts of its investment decisions on environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters by means of its policy on integration of ESG risks and value creation opportunities into the investment process. Moreover, Principles Adverse Impacts are monitored on a yearly basis through a yearly data collection on sustainability KPIs, which involves all portfolio companies.
Alpha will continue to review the evolution of SFDR regulations in relation to PAI and update accordingly this statement.
Remuneration Policy – Article 5
Alpha has set up a remuneration policy which is designed to promote sound and effective risk management and not to encourage risk-taking that is inconsistent with its risk appetite or the risk profiles of the portfolios which it manages. Alpha’s ESG Policy sets out how its investment process incorporates a consideration of ESG risks. Such risks form part of Alpha’s assessment of risk for the purposes of its remuneration policy.
Alpha’s approach to remuneration enables variable remuneration for employees to be adjusted for performance. This adjustment is not based solely on financial metrics. Qualitative nonfinancial performance metrics form a significant part of the assessment process. These metrics may include, for example, an employee’s failure to adhere to effective risk management, to comply with applicable regulatory rules, unethical behaviour or other behaviour that is contrary to Alpha’s Culture and Values. Consideration of these factors including where relevant an individual’s contribution to the Firm’s ESG-related efforts forms part of the employees’ performance assessment process.