Sustainability Related Disclosures in the Financial Services Sector "SFDR"
Updated October 2023
Credere Capital LLP SFDR Disclosure
Credere Capital LLP ESG Due Diligence Policy
Fund specific SFDR disclosures can be found on our strategies page here.
No Consideration of Sustainability Adverse Impacts
As a smaller investment firm (with fewer than 500 employees), Credere takes into account the adverse impacts of sustainability risks to the extent that such risks form an intrinsic part of other risks, such as market risk and operational risk. However, Credere does not consider this to amount to considering the adverse impacts on sustainability factors of investment decisions as set out under the SFDR.
The Funds do not promote environmental or social characteristics or have ‘sustainable investment’ as an objective, and Credere consider that the best interests of the Fund’s investors are served by following the investment objectives and policies of the Fund.
Credere plan to review its approach to the consideration and management of principal adverse impacts on an ongoing basis, building on its existing engagement and responsible investing practices.
Stewardship Code & Shareholders Rights Directive
Updated October 2023
The Firm has considered updates made to the Stewardship Code in January 2020 and the Shareholder Rights Directive II that took effect in June 2019.
The Financial Conduct Authority and the Financial Reporting Council have acknowledged that certain aspects of the Stewardship Code are not directly relevant to all managers.
The Firm is a fund manager to alternative funds; it does not adapt an active approach to shareholder participation. As such, the Firm has deemed compliance with the Code not to be relevant and has similarly chosen not to develop and publicly disclose an engagement policy.
The Firm’s Governing Body will continue to review the Code and Directive’s applicability.
Shareholders Rights Directive II
Updated October 2023
The Directive took effect in June 2019 and falls under COBS 2.2B in the UK. It applies, broadly, to Portfolio Managers, UCITS Management Companies and Full Scope AIFMs. The Directive requires firms that invest in shares that trade on an UK/EU regulated market, in addition to ‘comparable’ markets outside the UK/EU, to develop and publicly disclose an engagement policy or publicly disclose a clear and reasoned explanation of why it has chosen not to comply with this requirement.
Given the similarity with the UK Stewardship Code, which is at present not deemed relevant to the type of activity undertaken by the Firm, it has been decided not to comply with the Directive at the current time. However, this position is subject to annual review, in conjunction with the Stewardship Code, and any change to the current strategy of the Firm will be taken into account.
MIFIDPRU Disclosure
Updated October 2023
Credere Capital LLP (herein “Credere”) has adopted a remuneration policy and procedures that comply with the requirements of chapter 19B (AIFMD activities) and chapter 19G (MiFID activities) of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (“SYSC”), to the extent to which they apply.
Under MIFIDPRU 8, as a Small and Non-Interconnected (“SNI”) MiFID Investment Firm with no Additional Tier 1 Capital, Credere is required to provide an annual disclosure about its remuneration arrangements. The regulatory aim of the disclosures is to improve market discipline. This disclosure is in respect of the period ending 31st March 2023.
Remuneration Code
Summary of the firm's approach to remuneration for all staff
Credere’s overarching approach to remuneration is designed to encourage the alignment of the risks taken by the Firm’s Partners, its clients, mandates, and the Firm itself.
When Credere assesses individual performance to determine the amount of variable remuneration, it will consider both financial and non-financial criteria. As conduct is crucial to the compliance culture of the Firm, if a Partner shows poor conduct, this may override their performance in financial areas. Conduct is therefore the biggest metric within non-financial considerations.
Credere has concluded, on the basis of its size and the nature, scale and complexity of its legal structure and business, that it does not need to appoint a separate remuneration committee. Instead, the Firm’s Governing Body sets, and oversees compliance with, the Firm’s remuneration policy including reviewing the terms of the policy at least annually.
Key characteristics of its remuneration policies
Credere Capital LLP is a limited liability partnership and as such the Partners do not have fixed salaries. The Partners take Members drawings which are discretionary and variable.
The firm assesses performance across the firm, business units and individuals considering the following criteria:
• Financial metrics including contribution to revenue/ sales growth as well as cost reduction; and
• Non-financial metrics including: the building and maintenance of positive customer relationships and outcomes; alignment with our strategy or values, for example by displaying leadership, teamwork or creativity; adhering to our compliance policies & procedures; and meeting other non-financial targets relating to environmental, social and governance factors and diversity and inclusion.
In assessing performance, the above factors are considered at firm, business unit and individual level as applicable. Overall, greater weight is placed on non-financial metrics when assessing performance. All variable remuneration is adjusted in line with capital and liquidity requirements.
The Firm has adopted a remuneration policy and procedures that comply with the different chapters of the FCA’s Senior Management Arrangements, Systems and Controls Sourcebook (SYSC), and in accordance with ESMA’s Guidelines on sound remuneration policies. The Firm have considered all the proportionality elements in line with the FCA Guidance. All variable remuneration is adjusted in line with capital and liquidity requirements.
As a UK AIFM the Firm has assessed the proportionality elements and disapplies the Pay Out Rules. Furthermore, the Firm has concluded, on the basis of its size and the nature, scale and complexity of its legal structure and business that it does not need to appoint a remuneration committee. Instead, the Governing Body sets, and oversees compliance with, the Firm’s remuneration policy including reviewing the terms of the policy at least annually. The Firm make the following remuneration disclosure:
Quantitative information for the financial year ended 31st March 2023
Total Fixed Remuneration for all staff: 0
Total Variable Remuneration for all staff: 0
Credere has made no omissions on grounds of data protection.
* The above remuneration disclosure includes remuneration paid to Code Staff in respect to both their AIFMD and non-AIFMD activities. Credere Capital LLP is a limited liability partnership and as such the Partners do not have fixed salaries. The Partners take Members drawings which are discretionary and variable.
** As of October 2023
