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Sustainability

The EU Sustainable Finance Disclosure Regulation (“SFDR”) requires financial market participants to publicly disclose certain information. These disclosures in accordance with Articles 3, 4 and 5 are as follows: 

Information on integration of sustainability risks in the investment decision making process 

 

Nyhavn’s investment decision making is built on the foundations of effective and intelligent screening of the investment universe followed by in-depth fundamental analysis of the resultant investment ideas. The fundamental analysis undertaken by Nyhavn covers a broad spectrum of data points, including those commonly included under Environmental, Social and Governance standards – commonly referred to as Sustainability.

 

Nyhavn’s efforts to thoroughly investigate and engage with prospective investee companies, their clients, suppliers and other stakeholders provides a holistic view of the sustainability risks the investment might entail and thereby an opportunity to mitigate such risks or re-consider the size and / or timing of an investment.  

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Principal Adverse Impacts 

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SFDR requires Nyhavn to make a “comply or explain” decision whether to consider the principal adverse impacts (“PAIs”) of our investment decisions on sustainability factors, in accordance with a specific regime as outlined in SFDR.  

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Nyhavn is supportive of the EU’s policy aims of having financial market participants integrate consideration of adverse impacts of their investment decisions on sustainability factors. However, since Nyhavn manages discretionary portfolios on behalf of professional institutional investors and other financial market participants, the terms of each segregated mandate, including sustainability preferences, are negotiated on a case-by-case basis. Due to the custom nature of each segregated mandate, Nyhavn has decided not to consider PAI as described in the SFDR Regulatory Technical Standards at this time.   

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Nyhavn will reevaluate the decision on whether to consider PAIs each year or if new financial products are considered that have a sustainable investment objective

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Remuneration Policies in relation to the integration of sustainability risks

 

Nyhavn’s remuneration policy is in line with a sound and effective risk management framework, ensuring that the structure of remuneration does not encourage excessive risk-taking, including risks related to sustainability, and is underpinned by total risk-adjusted performance.  

30 June 2024

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