Saratoga Capital Management Ltd. has published this statement in compliance with EU Regulation 2019/2088 on “Sustainability-Related Disclosures in the Financial Services Sector”.
Current ESG Position
The company does not currently implement specific ESG principles at the entity level, nor do its funds have sustainable investment objectives under Article 9 of SFDR. However, management views ESG matters as of high importance and plans gradual integration into investment processes.
Sustainability Risk Integration
The company intends to review fund risk profiles to incorporate potential sustainability impacts through existing risk categories including:
- Market risk
- Operational risk
- Liquidity risk
- Credit risk
- Funding risk
- Reputational risk
Adverse Sustainability Impacts
The company acknowledges investments may be negatively affected by sustainability risks but does not currently assess adverse impacts on sustainability factors. The stated reasons are:
- Insufficient guidance
- Inadequate data quality
- Incomplete regulatory technical standards
Remuneration Policy
Compensation arrangements are designed to discourage excessive risk-taking, including exposure to sustainability risks, inconsistent with company risk profiles.
Pre-Contractual Disclosures
All documentation includes descriptions of how sustainability risks are integrated into decisions and assessments of likely financial impacts. Where risks aren’t relevant, explanations are provided.
Last Updated: January 1, 2026