SFDR Article 4

Explanation of non-compliance with SFDR’s principal adverse impacts regime

April 16, 2024

This document sets out disclosures by Kline Hill Partners LP (the “Firm”) in respect of the principal adverse impacts of our investment decisions on sustainability factors.

The EU Sustainable Finance Disclosure Regulation (“SFDR”) requires the Firm to make a “comply or explain” decision whether to consider the principal adverse impacts (“PAIs”) of our investment decisions on sustainability factors, in accordance with a specific regime as outlined in SFDR. The Firm has decided not to comply with that SFDR regime. The Firm is therefore required to publish and maintain on its website a statement to explain the reasons for not complying with the PAI regime in SFDR, and information as to whether and when we intend to comply with such regime.

  1. Non-compliance with the PAI regime in SFDR

    1. The Firm has carefully evaluated the requirements of the PAI regime in Article 4 SFDR, and in the draft Regulatory Technical Standards which were published in April 2020 (the “PAI regime”).
    2. The Firm 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 their investment decisions on sustainability factors. [However, the Firm manages funds which pursue a secondaries strategy and as such may lack access to suitable data in order to comply with the PAI regime.]
    3. The Firm will keep its decision not to comply with the PAI regime under regular review, and will formally re-evaluate the decision [annually].
  2. [Adherence to responsible business codes and international standards

    1. In connection with ESG, the Firm adheres to responsible business codes and internationally recognised standards for due diligence and reporting.]