SFDR Statement

General

Saratoga Capital Management Ltd. makes the following “Statement” in relation to the Transparency of Sustainability Risk Policies and Adverse Sustainability Impacts pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on Sustainability-Related Disclosures in the Financial Services Sector (“SFDR”).

Environmental, social, and corporate governance or “ESG” is a set of considerations, including environmental issues, social issues and corporate governance that can be considered in investing. Investing with ESG considerations is sometimes referred to as responsible investing or, in more proactive cases, impact investing.

This Statement in relation to SFDR and ESG may be updated from time-to-time. We therefore ask you to consult it on a regular basis. The last line below indicates when the Statement was last updated.

Integration of sustainability risks

As Saratoga Capital Management Ltd. qualifies as a “financial market participant” under SFDR, we have decided to publish on our website information about our policies on the integration of sustainability risks in its investment decisions-making process.

As of the date of this Statement, Saratoga Capital Management Ltd. does not consider specific ESG principles at the entity level nor does any of the our funds under management have sustainable investment as part of their respective investment objectives, strategies or policies for the purposes of Article 9 of the SFDR.

Notwithstanding the foregoing, Saratoga Capital Management Ltd. does consider ESG matters to be of high importance and intends to gradually integrate considerations and their implications within the investment assessment, decision-making process and risk exposure of each fund under management, unless otherwise stated in the relevant fund documentation.

Accordingly, Saratoga Capital Management Ltd. will implement processes on reviewing and re-assessing the risk profiles of its funds so as to integrate the potential impact of sustainability risks directly or indirectly through other, already-identified investment risks such as market risks, operational risks, liquidity risks, credit risk/counterparty risks, funding risks or reputational risks.

Transparency of adverse sustainability impacts

Saratoga Capital Management Ltd. acknowledges that certain of the investments that may be made by it on behalf of the funds it manages, may be negatively impacted by sustainability risks and that sustainability risks may impair the value of the investments made. However, Saratoga Capital Management Ltd. does not currently consider the adverse impacts of its investment decisions on sustainability factors, within the meaning of Article 4(1)(a) of the SFDR, as (i) Saratoga Capital Management Ltd. considers that for the time being, it does not have sufficient guidance or available data of satisfactory quality to do so and (ii) in view of the fact that the SFDR regulatory technical standards are not yet in final form.

Saratoga Capital Management Ltd. might reconsider its position in the future, subject to the availability of such guidance and data so as to take into account the adverse impacts on its investment decisions on sustainability factors.

Transparency of remuneration policy in relation to the integration of sustainability risks

It is the policy of Saratoga Capital Management Ltd. to maintain remuneration arrangements that, among other things, do not encourage risk-taking (including in respect of exposure to sustainability risks as defined in the SFDR) that is inconsistent with the risk profile of the company.

Transparency in pre-contractual disclosures

Where required by SFDR, all funds under management by Saratoga Capital Management Ltd. shall include relevant descriptions in its pre‐contractual disclosures – i.e., private offering memoranda, prospectuses or art. 23 AIFMD disclosures – on how sustainability risks are integrated into investment decisions, as well as the results of the assessment of the likely impacts of sustainability risks on the financial returns of funds under management.

Where sustainability risks are not deemed relevant, a clear and concise explanation of the reasons for such a decision are included. Further, where required, all funds under management by Saratoga Capital Management Ltd. shall include in their pre‐contractual disclosures a statement on how Principal Adverse Impacts (“PAI”) are considered or a statement that PAIs are not considered and the reasons therefor.

Update

If you have any concern about any aspect of our data protection and privacy policy or want to file a complaint and/or want us to provide you with any information regarding the processing of your personal data by Saratoga Capital Management Ltd., you may contact us via email at GDPR@saratogacap-mgt.com. 

This policy was last updated on 01.07.2024.