Citi - Manager Level Statement

Sustainable Finance Disclosure Regulation Information Integration of Sustainability Risk

The below disclosure applies to EU-based investors only. Article 3(1) of Regulation 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (as amended, “SFDR”) requires all financial market participants to publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process. “Sustainability risk” is defined in SFDR as “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 the investment.”

iCapital Global Alternatives, LLC (“iCapital”) is a financial market participant where it acts as the alternative investment fund manager (“AIFM”) for alternative investment funds offered within the European Union. In this context iCapital acts as an AIFM to ‘feeder’ funds which invest predominantly all of their assets into underlying third party ‘master’ funds and also as the AIFM of a fund of funds which invests in underlying third party funds.

iCapital makes the following disclosures in accordance with SFDR.

Integration of sustainability risks in investment decisions

“Sustainability Risk” is defined in SFDR as “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 the investment”.

iCapital acts as AIFM for funds that have been established solely for the purpose of investing in one or more underlying funds (“Underlying Funds”), and each fund’s investment strategy, which is determined at the time of establishment, reflects this. The investment in the Underlying Funds and any future investments in it are made in accordance with the pre-determined, existing investment strategy and accordingly there has been no specific investment decision to invest in the Underlying Funds and as such the AIFM is not able to integrate Sustainability Risks when investing in the Underlying Funds.

No Consideration of Sustainability Adverse Impacts

This disclosure is made for the purposes of Article 4(1)(b) of SFDR.

iCapital does not consider the adverse impacts of investment decisions on sustainability factors in respect of the alternative investment funds which it makes available in markets into the European Union. “Sustainability factors” are defined by SFDR as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. This is because typically, iCapital offers third-party funds (or feeder funds into third-party funds) whose managers are either not in scope of SFDR, or rely on an exemption from PAI entity reporting requirements. However, in some instances, the manager may consider the adverse impacts of investment decisions on sustainability factors.

iCapital recognizes this is an evolving area and we may modify our approach and as such, we may edit this page from time to time.