Environmental, Social & Governance

at Rhein Invest

No greenwashing. Just Sound citizenship.

Rhein Invest considers responsible investing self-evident and make investment decisions with sound citizenship in mind. Environmental, Social & Governance factors, in adherence with the United Nations Principles for Responsible Investing (UNPRI), are elementary considerations for all of our investments. Rhein Invest reviews hereto its policy on sustainability on a regular basis. The funds managed by Rhein Invest do not have a sustainable investment objective though, nor does it seek to promote environmental or social characteristics as referred to in articles 8 and 9 of the SFDR.

According to the Sustainable Finance Disclosure Regulation (“SFDR”) Rhein Invest is obliged to provide information on its website about the role of sustainability in its investment policy and investment decisions. The regulations aim to make the sustainability profile of funds more comparable and better understood by end-investors. In compliance with the SFDR, Rhein Invest informs its investors by means of this publication about the manner in which it integrates sustainability risks in its investment decisions, whether it considers adverse impacts of its investment decision on sustainability factors and the way in which sustainability risks are incorporated into its renumeration policy.

Sustainable Finance Disclosure Regulation

Risk Factors

In compliance with the SFDR, Rhein Invest integrates sustainability risks into its investment decisions. A sustainability risk means an environmental (E), social (S) or governance (G) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.

In managing its investment funds, investments are selected on the basis of the established investment policy. When selecting investments, numerous factors are taken into account that can affect the value of the investment. Because sustainability risks can (negatively) affect the value development, these aspects are included to the extent applicable. ESG risk factors are therefore integrated in the investment decision process and form part of the due diligence in the acquisition phase.

Sustainability risks in the ecological area include climate change, water scarcity and the use of natural resources. Social risks include product liability and respect for labor rights. Indirectly, the current funds managed by Rhein Invest might face reputational risks as a consequence of social risks (S). To manage the social risks, Rhein Invest selects reputable companies to invest in, which address ESG as part of their corporate strategy. In the area of governance, risks may arise with respect to remuneration, stability and diversity of directors, business ethics and shareholder rights. Rhein Invest addresses the governance risks (G) explicitly with customary legal documentation and through the board meetings.

Within the meaning of SFDR, sustainability factors are environmental, social and employment issues, respect for human rights, and the fight against corruption and bribery. When carrying out due diligence in respect of potential investments, Rhein Invest does not consider adverse impacts of investment decisions on sustainability factors as meant under the SFDR regulation. Consequently, Rhein Invest does not issue a principle adverse impact statement (“PAI-statement”).

In line with the explain-mechanism of article 4(1)(b) SFDR, Rhein Invest has the following considerations to not issue a PAI-statement. Rhein Invest believes that there is currently insufficient reliable data available to determine the potential effects of investments in relation to sustainability. Where detailed data is available, it is too expensive to obtain and time-consuming to analyze. Much remains unclear about the exact scope and content of the PAI-statement and the investment required from Rhein Invest to issue such PAI-statement. In addition, Rhein Invest does not give specific priority to sustainability factors over other factors that are important in managing its investments. In this view, Rhein Invest believes it is not proportionate in terms of time investment, costs and capacity to provide an PAI-statement. For this reason, Rhein Invest does not explicitly take into account the possible negative of investments on sustainability factors in the investment process and has no intention to do so in the near future.

No Consideration of Sustainability Adverse Impacts

Renumeration Policy

According to article 5(1) SFDR, Rhein Invest is obliged to publish information on its website about the consistency of the remuneration policy with integration of sustainability risks. Rhein Invest does not have (and, considering the AIFMD-light regime, is not obliged to have) a remuneration policy in place. Therefore, it is not possible to include information on the consistency of the remuneration policy with integration of sustainability risks.