Eric Sturdza Management Company S.A. (ESMC) is an independent Management Company in Luxembourg approved by the CSSF in 2016. The company is part of the Swiss banking group, Banque Eric Sturdza.
The company serves two UCITS, VIA AM SICAV and E. I. Sturdza Funds Plc domiciled in Luxembourg and Ireland respectively. Fund documentation is available on the websites of the delegated Investment Managers, VIA AM (www.via-am.com) based in Paris and E.I. Sturdza Strategic Management Ltd (www.ericsturdza.com) in Guernsey.
Eric Sturdza Investments
Banque Eric Sturdza
The following links provide more information on the operational procedures implemented and maitained by the ESMC.
Eric Sturdza Management Company (ESMC) is authorised by the Commission de Surveillance du Secteur Financier to provide UCITS Management Company services to a range of collective investment schemes domiciled in Luxembourg and Ireland.
As per Regulation (EU) 2019/2088 (“SFDR”), ESMC is defined as a “financial market participant”.
Per article 3 of SFDR a “financial market participant” shall publish information about their policies on the integration of sustainability risks in their investment decision-making process. “Sustainability risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.
Further, per Article 4 of SFDR a “financial market participant”, where the principal adverse impacts (“PAI”) of investment decisions are considered, is required to publish and maintain on its website a “statement on due diligence policies with respect to those impacts, taking due account of their size, the nature and scale of their activities and the types of financial products they make available”. This Statement has been developed in accordance with the provisions of Article 4, while also taking into consideration Article 7 of SFDR on the transparency of PAI at product level.
Delegation Model, Integration of Sustainability risk and Consideration of PAI (Article 3, Article 4 and Article 7 of SFDR)
ESMC delegates the Portfolio Management function of the funds to a qualified third party Investment manager (the “Investment Manager”). ESMC may retain the portfolio management function in certain instances and in that circumstance appoint systematically a third-party investment advisor. Therefore, in the majority of cases, “investment decisions” as defined under SFDR are delegated to these Investment Managers, subject to ESMC initial due diligence and ongoing oversight.
In accordance with the Commission Delegated Regulation (EU) 2021/1255 and Commission Delegated Directive (EU) 2021/1270 of 21 April 2021 , ESMC takes into account sustainability risks in the investment decision.
This is detailed in the pre-contractual disclosures in accordance with article 6 of SFDR.
Further, the Funds, to which ESMC act as UCITS Management Company, follow a number of different investment strategies with varying consideration of environmental, social and governance (ESG) and sustainability factors.
Article 3 – Sustainability Risks
ESMC ensures as part of its due diligence process and ongoing oversight that :
1. Sustainability Risks is an integral part of the Fund’s investment process;
2. Sustainability Risks is considered as part of a broader analysis of individual issuers, using internal and external inputs helping to identify exposure to Sustainability Risks, preparing for company engagement and collaborate on new research inputs based on data provided by data providers. The factors which will be considered by the Investment Manager will depend on the security in question, but typically include ownership structure, board structure and membership, capital allocation track record, management incentives, labour relations history, and climate risks.
3. In assessing these risks, the Investment Manager draws upon a wide variety of internal and external research to assess any potential impact on the value of the assets over the time horizon of the Fund.
In instances where ESMC retains Investment management and where a Financial Advisor is appointed, ESMC may consider sustainability risks within their investment decision in respect of those funds, provided that the steps described in 1-3 are fulfilled. ESMC also acknowledge that in certain instances, the Financial advisors may publish information on their own website in respect of sustainability risks integration.
ESMC has also enhanced its existing risk management framework to oversight the integration of sustainability risks. The risk management will oversee the integration of sustainability risks by Investment Managers on an ex-post basis.
Articles 4 & 7 – Principal Adverse Impact
ESMC does not consider Principal adverse impact (PAI) at entity level. However, ESMC and/or its delegates can consider the PAI on case by case at the level of funds.
Should Investment Managers wish to consider PAI in respect of the Funds in line with Article 7 of SFDR, ESMC shall ensure that:
1. The Delegated Manager has the appropriate infrastructure in place to report on PAI on an ongoing basis;
2. Where PAI are to be considered in respect of the Funds, the appropriate disclosures are made in the pre-contractual documents in line with SFDR by 31 December 2022;
3. The list of Funds for which PAI are considered is available on request;
4. The processes, systems and procedures in place to consider and report on PAI in respect of each Funds shall remain subject to the ESMC’ periodic due diligence;
5. The Investment Manager also provides or published on its website appropriate disclosures in accordance with Article 4(1) and (2) of SFDR, while also considering the associated Regulatory Technical Standards once adopted by the European Commission, in respect of the Funds;
6. The periodic reports of the Funds contain sufficient and appropriate information as to the assessment of PAI.
Where PAI are not considered in respect of the Funds to which ESMC act, ESMC shall ensure appropriate disclosures are contained within the relevant pre-contractual documents. For further information as to why PAI are not considered in respect of a particular Funds, please refer to the prospectus/supplement of that Funds.
In instances where ESMC retains Investment management, ESMC may consider PAI in respect of those funds, provided that the steps described in 1 to 6 of the above are carried out in an equivalent manner with appropriate disclosures made on its website. ESMC also acknowledge that in certain instances, the Financial Advisors may publish information on their own website in respect of PAI in respect of the Funds.
This position shall remain subject to ongoing review in line with market practise and regulatory developments. ESMC shall periodically reassess the integration of sustainability risks, PAI statements, policies adopted by the Investment Managers and reporting made in respect of the Funds to ensure their continued appropriateness.
These Statements are subject at least to annual review. For further queries relating to Eric Sturdza Management Company S.A. please contact: firstname.lastname@example.org
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