Our Impact

Manager-specific Website Disclosures in accordance with SFDR (as defined below)

These sustainability-related disclosures are made pursuant to Articles 3, 4 and 5 the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (“SFDR”).

Introduction

The SFDR sets out sustainability disclosure obligations for financial market participants, financial advisers and financial products. Under Articles 3 to 5 of the SFDR, Helios is required to make the following disclosures on its websites.

(1) Remuneration

Whilst Helios’ remuneration policy does not directly link the remuneration level of personnel specifically to consideration of ESG risks or compliance with ESG policies and procedures, indirectly remuneration levels of personnel may be impacted by such factors. Under Helios’ remuneration policy, remuneration is linked to, amongst other factors: (a) the financial performance of fund(s), portfolio(s) and/or investment(s); and (b) the personal performance of the individual employee and the performance of their team within the wider firm. Since risks, including ESG risks, can have a materially adverse impact on the financial performance of fund(s), portfolio(s) and/or investment(s), indirectly the remuneration level of personnel may be impacted by consideration, monitoring and management of ESG risks. The overall assessment of personal and team performance in determining remuneration levels for personnel takes into account compliance with all Helios’ policies and procedures, which include ESG policies and procedures related to investment activities, and accordingly compliance with such ESG policies and procedures may impact the remuneration level of Helios’ personnel.[1] (#_ftn1)

(2) Integrating sustainability risks

Helios’ investment process has been developed to enable Helios to make sound investment decisions that assesses ESG considerations. This is clearly documented and outlined in the Helios Responsible Investment Policy and the Helios ESG Management System (ESG-MS) Manual. Helios’ Pre-Investment Committee screening identifies initial material ESG concerns based on sector, geography and available information on the investee company and assigns a risk ranking based on the Helios defined risk categories. The due diligence requirements differ, depending on the risk associated with each deal.

The ESG Due Diligence will be conducted by external ESG specialists and Helios may conduct focused due diligence in areas such as climate, biodiversity/nature and human rights, where required. Helios ensures the adequate integration of the ESG Due Diligence findings in the investment decision-making process which includes the development of a corrective ESG Action Plan that is incorporated into the Shareholders Agreement for the new investment. Helios also ensures that investee companies comply with Helios’ ESG policies and actively monitor how an investee company is addressing ESG issues.

(3) No consideration of adverse impacts of investment decisions on sustainability factors

Helios does not consider the principal adverse indicators (“PAIs”) at the entity level under Article 4 SFDR. Helios has not elected to do so at the present time as there is insufficient data available to meaningfully measure against such PAIs. The detailed rules underlying the SFDR would require Helios to commit to gathering a substantial volume of data in line with the minimum mandatory PAI requirements of the SFDR which is currently not practicable due to limited, uncertain and scarce data being available. Helios will, however, gather data in order to monitor and report against its own identified key performance indicators and metrics. Helios will continue to review its position on the entity level PAIs on an ongoing basis to determine whether reporting on the PAIs could become feasible at some point in the future. However, Helios will consider PAIs at the product level with respect to certain Helios products.

(4) Ongoing review

Helios will review the website disclosures and ensure they are kept up to date.