Freshstream Investment Partners LLP
SFDR Disclosures
August 2024
Compliance with the SFDR regulation
Article 4: Consideration of Principal Adverse Impacts (PAIs) at the entity level
Freshstream takes sustainability and ESG very seriously, including through consideration of adverse impacts of an investment as part of its investment process; however, Freshstream does not consider the principal adverse impacts of its investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFDR. Freshstream is not currently in a position to obtain and/or measure all the data that it would be required by the SFDR to report on this basis, or to do so systematically, consistently, and at a reasonable cost. Freshstream does, however, monitor the SFDR’s principal adverse impacts indicators within the portfolio companies of its funds as part of the firm’s integrated approach to ESG. Freshstream believes that our existing due diligence processes and Responsible Investment Policy are appropriate for the investment strategies of our funds. We do and will continue to monitor regulatory developments, including with respect to the SFDR, and where required will make changes to our existing policies and procedures if appropriate.
Article 5: Integration of sustainability factors in the remuneration policy at the entity level
Freshstream pays its staff a combination of fixed remuneration, which takes into consideration a variety of qualitative and quantitative factors, including sustainability, as described above.
Governance and Oversight
The Management Committee is responsible for setting and overseeing the implementation of Freshstream’s practices. In order to fulfil its responsibilities, the Management Committee:
- Is appropriately staffed to enable it to exercise competent and independent judgment on remuneration practices and the incentives created for managing risk, capital, and liquidity.
- Prepares decisions regarding remuneration, including decisions that have implications for the risk and risk management of the Firm.
- Ensures that the Firm’s remuneration practices take into account the public interest and the long-term interests of shareholders, investors, and other stakeholders in the Firm.
- Ensures that the overall remuneration practice is consistent with the business strategy, objectives, values, and interests of the Firm and of its clients.
Freshstream’s remuneration practices are reviewed annually by the Management Committee.
Quantitative Remuneration Disclosure
For the financial year ended 31 March 2024, the total amount of remuneration awarded to all staff was £4.8m. The ratio between fixed and variable component (including bonus) is approximately 2:5. For these purposes, ‘staff’ is defined broadly, and includes, for example, employees of the Firm itself including its overseas offices, and any salaried partners of the Firm.