EU Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (“SFDR”) imposes new transparency obligations and periodic reporting requirements on investment management firms (includes managers of alternative investment) at both a product and firm level. 

The SFDR forms part of the European Commission's action plan on sustainable finance.

Policy on the integration of sustainability risks

Sustainability risks, being environmental, social or governance events or conditions that, if they occur, could cause a negative material impact on the value of the investments, are considered by Hamilton Lane in its investment processes and due diligence procedures.

Hamilton Lane’s ESG Investment Policy Statement describes how the Firm integrates sustainability risks into its investment decision process.

See our ESG Investment Policy Statement here.

Consideration of principal adverse impacts

While supportive of the policy aims of the principal adverse impact regime, Hamilton Lane does not currently consider the adverse impacts of its investment decisions on sustainability factors as there are still a number of uncertainties regarding this obligation, in particular because the relevant regulatory technical standards have not yet been finalized by the European authorities. 

This decision will be kept under review pending the publication of the final regulatory technical standards and further details will be provided in due course.

Hamilton Lane’s Remuneration Policy

The Firm’s Remuneration Policy contains appropriate information on how the Remuneration Policy is consistent with the integration of sustainability risks.

The Remuneration Policy has been adopted by the Firm’s Managing Member in accordance with binding rules implementing EU directive 2011/61/EU on Alternative Investment Fund Managers and relevant implementing regulations (together, the AIFMD), and in accordance with the principle of proportionality.

The Remuneration Policy is available upon request.

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