Information for investors in undertakings for collective investment managed by GERIFONDS (Luxembourg) SA (hereinafter "the Company")
General sustainability guidelines
1. Legal and regulatory framework
EU Regulation 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector ("SFDR"), lays down harmonised rules for EU financial market participants on transparency in the integration of sustainability-related risks and the consideration of adverse sustainability impacts in their process and the provision of sustainability-related disclosures in relation to financial products.
EU Regulation 2020/852 of the European Parliament and of the Council on the establishment of a framework to promote sustainable investments ("Taxonomy"), amending SFDR, aims to inform investors about the ecologically sustainable nature of an economic activity by setting criteria common to the entire European Union.
The aim of these regulations is to provide greater transparency and to differentiate financial products according to their degree of sustainability.
2. Obligations of the Company to publish information
According to Article 3 of the SFDR, the Company is required to publish on its website information regarding its policy on integrating sustainability risks into its investment decision-making process.
The Company has established a policy for integrating sustainability risk into its investment decision-making process. This policy provides a description of the activities carried out towards the integration of sustainability criteria, as defined by the SFDR and Taxonomy regulations, in managing the investments of the funds or sub-funds for which GERIFONDS (Luxembourg) SA acts as management company.
The Company has integrated sustainability risks into its overall risk management.
"Sustainability risk" means an environmental, social or governance event or situation that, if it occurs, could have a material adverse effect, actual or potential, on the value of the investment.
3. Negative impacts on sustainability
In accordance with Article 4 of the SFDR, the Company must disclose whether, and how, it considers the Principal Adverse Impacts ("PAI") of investment decisions on sustainability factors.
In the opposite case, which is that of GERIFONDS (Luxembourg) SA, the Company must explain the reasons why it does not do so.
In general, and with the exception of the products listed below, for which this is specified, GERIFONDS (Luxembourg) SA does not take into account the main negative impacts of investment decisions on sustainability factors.
|
Funds |
Sub-fund |
SFDR Classification |
Consideration of "PAIs" in investment decisions |
| BCV FUND (LUX) | BCV Liquid Alternative Beta ESG | 8 | No |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) World Bonds (CHF) | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) World Bonds (EUR) | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) World Bonds (USD) | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) Liquoptimum (CHF) | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) Liquoptimum (EUR) | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) Liquoptimum (USD) | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) World Credit Opportunities | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) Swiss All Caps (CHF) | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) Swiss Small & Mid Caps (CHF) | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) World QualiLife Stocks | 8 | Yes |
| SYNCHRONY (LU) FUNDS | Synchrony (LU) EU All Caps | 8 | Yes |
| BCV FUND (LUX) | Ethos Climate ESG Ambition | 9 | Yes |
This is essentially linked to the size, organisation, nature and scope of the activities carried out by the Company and finally to the type of financial products it offers.
When delegating the portfolio management function to a third party, GERIFONDS (Luxembourg) SA performs the evaluation, monitoring, validation and reporting/disclosure of PAIs in accordance with the investment strategy and applicable laws and regulations, in particular with reference to each managed fund falling within the scope of Article 8 of the SFDR (i.e. favouring environmental and social characteristics) and funds falling within the scope of Article 9 of the SFDR (i.e. promoting sustainable investments).
Investors should note that it is very difficult to assess with reasonable certainty the existence or likely outcome of a sustainability risk on investments and/or its impact on the Funds.
Each Fund must comply with its investment policy and objectives, as well as the general investment restrictions as described in the Funds' prospectuses and management regulations.
4. Integration of sustainability risks in the remuneration policy
In accordance with Article 5 of the SFDR, the Company has included sustainability risks in its remuneration policy.
These principles apply both to the remuneration model of GERIFONDS (Luxembourg) SA and to the model adopted by its delegated managers.
Sustainability risks are considered in particular within the general framework of a good governance practice, and through performance evaluation in the case of variable remuneration. All employees receiving variable remuneration are assessed on the basis of qualitative criteria corresponding to their duties and responsibilities.
Employees' performance is thus measured according to their compliance and risk-related results, including sustainability risks, which require compliance with regulatory or even self-regulatory obligations set out in our internal policies.
5. Integration of sustainability risks
In connection with Article 6 of the SFDR, the Company must also describe how potential sustainability risks are incorporated into its investment decisions.
Most of the funds or sub-funds managed by the Company are categorised according to this Article 6 of the SFDR. For these investors, taking into account the diversity of investments and the strategies implemented, sustainability risks may be considered among other elements of analysis in the investment decision but are not the determining criteria that define the framework of the investments actually held.
The funds or sub-funds managed by the Company and categorised according to Article 8 of the SFDR incorporate certain sustainability characteristics into their investment process.
Lastly, the sub-fund managed by the Company and categorised according to Article 9 of the SFDR has a sustainable investment objective, contributing to an environmental or social objective.
For these last two categories of funds or sub-funds, the following information on transparency requirements in terms of sustainability is available on this website, in the section "Documents" referring to each class of units or equities:
- a document describing how these characteristics or objectives are integrated;
- a pre-contractual information document; and
- a periodic report.
6. Taxonomy
The investments of funds or sub-funds managed by GERIFONDS (Luxembourg) SA do not take into account the criteria of the Taxonomy Regulation of the European Union regarding sustainable economic activities.
Sustainability information on the financial products offered by the Company
1. BCV FUND (LUX)
BCV FUND (LUX) is an umbrella investment fund with multiple sub-funds. It comprises 16 sub-funds, including:
- 14 sub-funds are categorised according to Article 6 of the SFDR. These sub-funds incorporate sustainability risks into their investment process, but do not make binding commitments, do not promote environmental and/or social characteristics and do not aim to invest sustainably;
- 1 sub-fund is categorised according to Article 8 of the SFDR. This sub-fund promotes social and/or environmental characteristics, invests in companies that respect good governance, makes binding commitments, but has no sustainable investment objective;
- 1 sub-fund is categorised according to Article 9 of the SFDR. The objective of this sub-fund is to invest sustainably or reduce carbon emissions and makes binding commitments.
A. BCV Liquid Alternative Beta ESG (Article 8 of the SFDR)
In accordance with Article 8 of the SFDR, the sub-fund promotes a combination of environmental and social characteristics, while complying with good governance rules, by exposing itself to best-in-class ESG (environmental, social and governance) indices produced by MSCI.
The integration of ESG criteria in the BCV Liquid Alternative Beta ESG sub-fund is therefore applied through its exposure to ESG indices produced by MSCI via total return swaps (TRS).
Index construction by MSCI includes the following approaches:
- exclusion of serious controversies and controversial sectors: alcohol, gambling, tobacco, nuclear energy, conventional weapons, nuclear weapons, controversial weapons, civilian firearms, extraction of fossil fuels and thermal coal, etc.
- "best-in-class": only securities with the best ESG profiles (on average 50% of the market capitalisation/market value of each sector and region within the parent index, based on ESG ratings) are selected from the indices.
In all selected ESG indices:
- securities must have an MSCI ESG rating of "BB" or higher to remain in the index;
- the securities must have an MSCI ESG "Controversies" score of 1 or higher to remain in the index.
It should also be noted that issuers whose ESG rating and/or "Controversies" score are downgraded below the defined threshold are only removed from the MSCI indices during periodic index reviews.
MSCI assesses the ESG profile of each stock retained in the selected indices by using a proprietary methodology.
Non-ESG investments are those for which the factors used in the business model (e.g. currency pairs or government bonds of developed countries) do not present "investable" alternatives according to these criteria. The fund's liquid assets invested in sight and/or term deposits, money market instruments, short-term debt securities/bonds (i.e. with a residual maturity of three years or less), UCITS/other money market funds and/or UCITS/other funds with a short-term bond strategy are also not subject to ESG approaches.
Additional information on the environmental or social characteristics of the sub-fund is available in the "Pre-contractual information" and "Periodic reports" appendices of the fund prospectus, which can be viewed on this same website.
B. Ethos Climate ESG Ambition (Article 9 of the SFDR)
The sub-fund pursues a sustainable investment objective within the meaning of Article 9 of the SFDR.
The objective of the Ethos Climate ESG Ambition sub-fund is to apply a capital growth strategy by investing primarily, without geographical constraints, in equities of companies whose products and services have a positive environmental impact and contribute directly or indirectly to the energy and ecological transition and reduction of the impacts of climate change.
The sub-fund invests in business sectors considered crucial for the energy and ecological transition, in the form of products and services. These activities are mainly grouped around the following themes considered by Ethos (the Investment Advisor) as having a positive environmental and/or social impact and playing a key role in the transition to a sustainable economy:
- sustainable energy;
- low-carbon mobility;
- sustainable real estate;
- resilient agriculture, aquaculture and forestry;
- circular economy;
- sustainable water management;
- pollution control.
In carrying out its assessment, Ethos takes into account the Principal Adverse Impacts (PAI), in accordance with Appendix I to Commission Delegated Regulation (EU) 2022/1288, as well as the principle of Do Not Significantly Harm (DNSH).
Ethos applies a three-step process to identify companies with a positive impact, as described below:
First step: through exclusion criteria
The sub-fund excludes companies whose revenue exceeds a non-negligible threshold in the following activities/sectors:
| conventional weapons | 5% |
| non-conventional weapons | 0% |
| thermal coal | 5% |
| unconventional oil and gas, i.e. shale gas and oil, Arctic gas and oil, oil sands, unconventional gas or oil pipelines | 5% |
| nuclear energy (5%) and (5%). | 5% |
| tobacco | 5% |
| genetically modified organisms in agrochemicals | 5% |
| gambling | 5% |
| adult entertainment | 5% |
| companies whose revenues are derived from the exploration, extraction, production and refining of conventional oil and gas | 5% |
| companies whose revenues are derived solely from the distribution to end customers of natural gas or electricity produced from conventional oil or gas. The latter category mainly includes utilities. | 20% |
Second step: through a best-in-class approach
Ethos evaluates companies using a standard multi-criteria quantitative approach using approximately 100 ESG data points divided into three main categories: governance, strategy and reporting, and stakeholders. Each company is assigned an ESG score based on the above criteria.
Third step: through a positive impact assessment
Ethos identifies companies whose products and services have a positive environmental impact on the environment and contribute directly or indirectly to the energy and ecological transition and reduction of the impacts of climate change. The positive impact measurement is determined on the basis of an estimate of each company's revenue generated in the various business themes (mentioned above) contributing to the energy and ecological transition and the fight against climate change.
The sub-fund invests only in companies considered sustainable. These investments represent at least 90% of the sub-fund's assets.
In addition, the sub-fund complies with the following investment constraints:
- at least 33% of the sub-fund's investments (i.e. at least 30% of the sub-fund's assets) are in companies that generate more than 50% of their revenue from activities related to the energy and ecological transition and the fight against climate change;
- at least 66% of the sub-fund's investments (i.e. at least 60% of the sub-fund's assets) in companies that derive more than 20% of their revenue from activities that contribute to the energy and ecological transition and the fight against climate change.
Additional information on the environmental or social characteristics and the ESG analysis and rating methodology used by the sub-fund are available in the "Pre-contractual information" and "Periodic reports" appendices of the fund's prospectus, which can be viewed on this same website.
2. SYNCHRONY (LU) FUNDS
SYNCHRONY (LU) FUNDS is an umbrella fund with multiple sub-funds. This fund has 17 sub-funds, including:
- 6 sub-funds categorised according to Article 6 of the SFDR. These sub-funds incorporate sustainability risks into their investment process, but do not make binding commitments, do not promote environmental and/or social characteristics and do not aim to invest sustainably;
- 11 are categorised according to Article 8 of the SFDR. These sub-funds promote social and/or environmental characteristics, invest in companies that respect good governance, make binding commitments but do not have a sustainable investment objective.
A. Sub-funds categorised according to Article 8 of the SFDR
- Synchrony (LU) World Bonds (CHF)
- Synchrony (LU) World Bonds (EUR)
- Synchrony (LU) World Bonds (USD)
- Synchrony (LU) Liquoptimum (CHF)
- Synchrony (LU) Liquoptimum (EUR)
- Synchrony (LU) Liquoptimum (USD)
- Synchrony (LU) World Credit Opportunities
- Synchrony (LU) Swiss All Caps (CHF)
- Synchrony (LU) Swiss Small & Mid Caps (CHF)
- Synchrony (LU) World QualiLife Stocks
- Synchrony (LU) EU All Caps
The sub-funds mentioned above promote environmental and/or social characteristics within the meaning of Article 8 of the SFDR by defining the importance of environmental, social and governance (ESG) risks and opportunities for the majority of investments. This information is integrated by the sub-funds into their investment processes through a positive orientation approach established and followed by the portfolio manager.
In addition, a regular check is carried out on the securities in the portfolio with regard to compliance with the principles of the United Nations Global Compact.
Additional information on the environmental or social characteristics of the sub-fund is available in the "Pre-contractual information" and "Periodic reports" appendices of the fund prospectus, which can be viewed on this same website.
3. Funds or sub-funds categorised according to Article 6 of the SFDR
All other funds or sub-funds managed by the Company, mentioned below, do not fall within the scope of Article 8 or Article 9 of the SFDR.
These funds or sub-funds, known as "Article 6", have no explicit sustainability objective. They are not subject to specific sustainability transparency requirements. "Article 6" funds or sub-funds may invest in companies and sectors that do not comply with environmental, social and governance (ESG) criteria.
These funds or sub-funds, through their portfolio managers, do not incorporate sustainability risks and opportunities into their respective research, analysis and investment decision-making processes. Portfolio managers believe that consideration of sustainability risks and opportunities does not have a material impact on the long-term strategy of such funds or sub-funds.
These funds or sub-funds do not take into account the principal adverse impacts, as well as the principle of do not significantly harm, in their investment decisions regarding sustainability factors.
The underlying investments of these funds or sub-funds do not take into account the criteria for environmentally sustainable economic activities defined by the EU Taxonomy Regulation.
| BCV FUND (LUX) |
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| BCVs / WKB (LU) FUNDS |
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| BCV REAL ESTATE FUND | Global
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| BPSA FONDS LUX |
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| DMC FUND |
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| PIGUET GLOBAL FUND |
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| SYNCHRONY (LU) FUNDS |
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| SYNCHRONY PRIVATE EQUITY FUND OF FUNDS WORLD |
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| PIGUET STRATEGIES |
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| PIGUET INTERNATIONAL FUND |
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Updated information as at 16 April 2024.