Sustainability-related disclosures: SFDR

Here we set out our policies and disclosures under the EU Sustainable Finance Disclosures Regulation (SFDR).

Please note, this information relates only to the Artemis Funds (Lux) range of funds, which are domiciled in Luxembourg, regulated by the CSSF and are within the scope of SFDR.

EU Sustainable Finance Disclosures Regulation

The EU Sustainable Finance Disclosures Regulation (SFDR) is a set of European Union rules which aims to improve transparency around the sustainability profile of funds and to allow for better comparison between funds.

SFDR helps categorise funds into specific groups and includes disclosures and metrics for assessing the environmental, social and governance (ESG) impacts of the investment process for each fund.

The information below describes our approach to SFDR and includes our policies, procedures and the relevant disclosures.

Classification of funds under SFDR

One key element of SFDR is the reporting format that funds are required to follow depending on whether they meet the criteria for Article 8 or Article 9 of SFDR.

• Article 8 funds are those which promote environmental or social characteristics, or a combination of those characteristics, provided the companies in which investments are made follow good governance practices.
• Article 9 funds are those that have sustainable investment as their objective and target sustainable investments.
• Funds which do not fall within the scope of Article 8 or Article 9 are ‘neutral’ funds, which do not have any binding sustainability controls in their investment process and may not be promoted as ESG funds.

The Artemis funds (Lux) range of funds has a number of Article 8 funds.

Fund-level sustainability disclosures are available below.

Integration of sustainability risks

SFDR defines sustainability risk as an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment.

As an investment manager, Artemis is a steward of clients’ capital and acts in their interests to invest in companies which can create, preserve and enhance value. This involves the assessment of a broad range of factors which do, or could, have an impact on value, including those related to environmental, social and governance (“ESG”) drivers.

At the investment fund level, it is the responsibility of each investment team to effectively manage the sustainability risks that could impact the value of the portfolios that they manage. To achieve this, Artemis’ investment teams are supported by the Stewardship team who work them to help integrate sustainability considerations into the investment processes and further those goals through stewardship activities, including engagement. Their role is to provide insight, discuss and challenge the individual sustainability approaches of each investment team.

Each of our investment teams integrate material sustainability risks into their investment decision-making process, although individual funds may have different approaches to how, and to what extent, sustainability risks are considered depending on relevance to their investment strategy and any particular sustainability-related characteristics of the fund. We seek to assess sustainability risks alongside other types of investment risks which may be financially material, such as credit or market risks. The factors which are relevant to this assessment will vary depending on the investment strategy, asset class, geographic focus, investment holding period, portfolio positioning and construction and risk tolerance of individual funds and strategies, as well as company-specific factors. The presence of actual or potential sustainability risks does not in itself necessarily preclude investment in a company, but rather helps investment teams to assess the overall risk profile of a company as part of their investment analysis. 

Artemis sustainable investment methodology for SFDR

Artemis’ current approach to defining ‘sustainable investments’ for the purposes of SFDR is explained in our Sustainable investment methodology. This Sustainable Investment methodology is reviewed on a regular basis. The SFDR regime is fast-evolving and subject to frequent regulatory updates and clarifications. Artemis reviews this methodology as new regulatory guidance emerges and industry best practice evolves, and we revise our approach to take account of new regulatory and industry developments as we deem appropriate.  

Statement on principal adverse impacts of investment decisions on sustainability factors

Under SFDR, firms are required to provide annual disclosures on the principal adverse impacts of investment decisions, which are available here. The English version contains a full statement, whilst versions in other languages contain a summary only:

Fund sustainability-related disclosures

Sustainability-related disclosures for each of our Artemis Funds (Lux) funds, as required under Article 10(1) of SFDR for funds which fall within the scope of Article 8 or Article 9 of SFDR, are available here. The English versions contain the full set of disclosures for each fund, whilst versions in other languages contain summaries only:

Artemis Funds (Lux) prospectus

This is intended to provide you with information about sustainability aspects of the Artemis Funds (Lux) range of funds. It is not a marketing communication and should not be used to make investment decisions. You should always refer to the relevant fund prospectus and KIID/KID before making any final investment decisions.

Artemis does not provide investment advice on the advantages or suitability of its products and no information provided should be viewed in this way. Should you be unsure about the suitability of an investment, you should consult a suitably qualified professional adviser.

Issued by: Artemis Fund Managers Limited and Artemis Investment Management LLP which are authorised and regulated by the UK Financial Conduct Authority; in Germany, AI Management (Europe) GmbH; in Switzerland, Artemis Investment Services (Switzerland) GmbH.