SFDR Article 3

Summary of the Firm’s Sustainability Risks Policy

April 16, 2024

  1. Introduction

    1. This disclosure statement sets out a summary of the policies of Kline Hill Partners LP (the “Firm”) on the integration of sustainability risks in its investment decision-making process.
    2. The Firm has implemented an ESG Policy (the “Policy”), which sets out the Firm’s policies in respect of the integration of sustainability risks in its investment decision-making process, as required by the Sustainable Finance Disclosure Regulation (“SFDR”). This document provides a summary description of the key features of the Policy, for the purposes of disclosure on the Firm’s website.
    3. Under SFDR, “sustainability risk” means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.
  2. Sustainability risk management

    1. The Firm is dedicated to integrating ESG considerations into its investment decision-making process. The consideration of sustainability risks would not necessarily cause or prevent the Firm from making an investment but would form part of the broader, discretionary assessment made by the Firm in respect of the risks associated with a prospective investment.
    2. The Firm’s investment strategy primarily involves the secondary market, where participants have limited influence over fund sponsors and investment managers in respect of ESG matters. However, pursuant to the Policy, the Firm seeks to integrate sustainability risks across the following aspects of the investment process: (i) Investment Analysis & Due Diligence; (ii) Ownership; (iii) Governance & Oversight.
    3. Investment Analysis & Due Diligence

      The Firm acknowledges that ESG considerations can represent material risks and opportunities with the potential to impact fund value. The Firm seeks to develop a comprehensive understanding of ESG considerations during the due diligence process (including aggregating data through fund reporting, market research, and professional advice) and aims to record information on material ESG considerations as part of this process.

    4. Ownership

      To the extent a significant ESG issue were to arise in respect of an investment, the Firm would seek to work with underlying funds to comprehend and address these matters. The Firm intends to use its influence to encourage fund managers to address ESG issues.

    5. Governance & Oversight

      The Firm’s ESG Committee manages the implementation of our ESG policy and its integration into our investment process. The ESG Committee reviews practices, discusses improvements, and tracks progress towards ESG targets. The Firm’s Investment Committee holds ultimate responsibility for managing significant ESG issues in investment decision-making.

  3. Status of this document

    This disclosure statement is provided for information purposes only. In the event of any inconsistency between this disclosure statement and the terms of the Policy or any agreement between the Firm and any of its clients, such other document shall prevail. No person should take (or refrain from taking) any action as a result of this disclosure statement. To the maximum extent permitted by law, no liability is accepted by the Firm in respect of this disclosure statement.