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Responsible Investment Principles

Governance

Key elements of Beyond Capital Partners’ ESG Governance:



Principal adverse impacts statement (“PAI”)

The Sustainable Finance Disclosure Regulation (“SFDR”) requires Beyond Capital Partners to make a "comply or explain" decision whether to consider the principal adverse impacts ("PAIs") of its investment decisions on sustainability factors, in accordance with a specific regime outlined in SFDR. The Sustainable Finance Disclosure Regulation (“SFDR”) requires Beyond Capital Partners to make a "comply or explain" decision whether to consider the principal adverse impacts ("PAIs") of its investment decisions on sustainability factors, in accordance with a specific regime outlined in SFDR. Beyond Capital Partners has opted not to comply with that regime, both generally and in relation to the Funds. Beyond Capital Partners will keep its decision not to comply with the PAI regime under regular review.

Beyond Capital Partners has carefully evaluated the requirements of the PAI regime in Article 4 of the SFDR, and in the draft Regulatory Technical Standards which were published in April 2020 (the "PAI regime"). Beyond Capital Partners is supportive of the policy aims of the PAI regime, to improve transparency to clients, investors and the market, as to how financial market participants integrate consideration of the adverse impacts of investment decisions on sustainability factors. However, Beyond Capital Partners is concerned about the lack of readily available data to comply with many of the reporting requirements of the PAI regime, as Beyond Capital Partners believes that companies and market data providers are not yet ready to make available all necessary data for the PAI regime.

Notwithstanding Beyond Capital Partners’ decision not to comply with the PAI regime, Beyond Capital Partners has implemented positive ESG-related initiatives and policies, as part of its overall commitment to ESG matters, as summarized above. For the avoidance of doubt, none of the information is intended to suggest that Beyond Capital Partners complies with the PAI regime.



Remuneration Policy

Beyond Capital Partners (along with its subsidiaries and controlled affiliates) has established a remuneration policy (the "Policy") applicable to all Beyond Capital Partners entities. The Policy is developed, approved, implemented and monitored by the Managing Partners. The Policy applies to all employees of Beyond Capital Partners, save for limited exceptions.

The Policy has been developed with the aim of supporting Beyond Capital Partners' business strategy, corporate values and long‐term interests, including by facilitating the identification, assessment and management of sustainability risks when determining individual remuneration packages. The key principles of the Policy include fostering appropriate risk culture (including with respect to the management of actual and potential conflicts of interest) and compliance with applicable law and regulation.

The performance management and rewards framework envisioned by the Policy has been designed to promote effective risk management, including in particular by: