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The Sustainable Finance Disclosure Regulation (SFDR)
The SFDR is part of a package of measures introduced to implement the EU action plan on sustainable finance
( ) which aims to push more capital towards sustainable activities.
The SFDR introduces various mandatory disclosure-related requirements for financial market participants and financial advisors at entity, service and product level in relation to the firm’s approach to ESG matters, covering “Sustainability Risks”, defined as any environmental, social or governance events or conditions, including but not limited to climate change, which could cause a material negative impact on the value of an investment; “Principal Adverse Impacts”, defined as any negative effects that investment decisions or advice could have on sustainability factors; and additional requirements for products that promote ESG characteristics or that have sustainable investment objectives.
The financial year to 31 December 2020 has been a very challenging period, during which the COVID-19 pandemic and the protective measures that were subsequently introduced, have had a significant impact on the economy, whilst also affecting the personal and working lives of most people. This global health crisis has had a wide reaching impact across our society and the thoughts of the Directors are with all of those who have been affected.
Against this economic backdrop, it is encouraging to report on the positive progress that has been achieved by your Company, with NAV total return at the year end increasing to 148.93p per share. This growth reflects the strength and resilience of the underlying portfolio, and the ability of investee companies to adapt to the evolving market conditions. The AIM quoted portfolio made a strong contribution to the overall performance with most investee companies reporting positive trading updates, which resulted in share price appreciation. C
The European Commission published a
30 March
FSB”) published a
speech made by Randal Quarles, FSB Chair, that sets out details of the FSB s areas of focus for 2021.
European Securities and Markets Authority (“
ESMA”) published an updated version of its
Q&As (ESMA34-32-352) on the application of the Alternative Investment Fund Managers Directive (EU/2011/61) (“
AIFMD”).
HM Treasury published a
statement concerning the first meeting of the Joint Committee established under the UK-US bilateral agreement on insurance and reinsurance prudential measures.
ESMA published its
final report (dated 23 March 2021) (ESMA74-362-1013) on reference data and transaction reporting obligations under the Markets in Financial Instruments Regulation (600/2014) (“
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On 2 August 2021, changes to fund marketing rules will come into effect in the European Union (“
EU”). The revised rules (the “
Marketing Rules”) amend the existing regime relating to the marketing of alternative investment funds (“
AIFs”) under the Alternative Investment Fund Managers Directive (2011/61/EU) (“
AIFMD”). These changes are brought into effect by EU Regulation 2019/1156 and EU Directive 2019/1160.
The following summarises the key proposals under the Marketing Rules that are expected to impact alternative investment fund managers (“
AIFMs”) below.
Harmonised definition of “pre-marketing”
The Marketing Rules provide a definition of what “pre-marketing” means across EU Member States. Under the current regime, approval is required only where fund promotional activities would fall with the AIFMD definition of “marketing”. However, EU Member States take divergent views as to