Sustainability disclosures

Published in accordance with Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR).

Integration of sustainability risks

A sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause a material negative impact on the value of a sub-fund’s investment. It can be a risk of its own or affect other risks, such as market, operational, liquidity or counterparty risk, and may affect long-term risk-adjusted returns.

Assessing them is complex and may rely on environmental, social or governance data that is hard to obtain, incomplete, estimated, out of date or inaccurate. Even when identified, there is no guarantee that these risks are assessed correctly.

Approaches to sustainable finance have no common standards, can be subjective and continue to evolve, including through regulation, which makes products hard to compare. For these reasons, Gyra Funds Lux has chosen not to be an ESG fund.

Exclusions

GYRA does not invest in sovereign bonds issued by countries subject to a UN Security Council arms embargo, nor in companies involved in manufacturing landmines, chemical or biological weapons, or nuclear weapons in breach of the Treaty on the Non-Proliferation of Nuclear Weapons.

Principal adverse impacts

Unless disclosed otherwise on this website at a later stage, GYRA does not consider the adverse impacts of its investment decisions on sustainability factors, mainly because the data needed to assess them adequately is not available.

Remuneration policy

Gyra S.A.’s current remuneration policy does not fully consider sustainability risks, with the exception of certain measures. It combines fixed pay with an annual discretionary bonus based on individual performance, the performance of the relevant product, and adherence to internal procedures, policies and compliance requirements, which may include sustainability considerations. The policy is reviewed regularly.

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