Under the EU Sustainable Finance Disclosure Regulation (EU 2019/2088) (SFDR) we are required to make the following disclosures where one of our non-EU funds is managed by one of our US entities (麻豆社 Asset Management (Americas) LLC., 麻豆社 Realty Investors LLC, 麻豆社 Farmland Investors LLC) and marketed to EU investors:

  1. Integration of Sustainability Risk: Sustainability risks are financial risks that are defined as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment (art. 2 para. 22 SFDR). 麻豆社 believes that sustainability risks may affect the performance of investment portfolios. To enhance the long-term performance of clients' investments, 麻豆社 integrates sustainability risk into its investment decision making process聽where relevant. The integration of sustainability risk is implemented in line with 麻豆社 AM鈥檚 policies governing the creation of investment research views, portfolio construction and product selection.
  2. Remuneration: 麻豆社鈥檚 approach to compensation globally is underpinned by the Total Reward Principles, which establish a framework with a focus on conduct and sound risk management practices. Employees are assessed and rewarded for their performance against a range of financial and non-financial goals, including risk management. Where applicable (which may include where US employees are working on non-EU funds that are marketed into the EU), the risk management goal will include a consideration of sustainability risk. Where sustainability risks form part of an employee鈥檚 performance objectives, they are taken into account in the qualitative performance assessment, which, in turn, is one of the factors that determines an employee鈥檚 total remuneration.聽
  3. No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors:聽The 麻豆社 US entities do not consider any principal adverse impacts (PAI) of investment decisions on sustainability factors as set out in SFDR and do not currently intend to do so in the future. Considering that the 麻豆社 US entities鈥 offerings are predominantly targeted at the US market, and that only some products are marketed to EU investors and/or may consider certain adverse impacts in the investment decision, it would be disproportionate to apply the PAI framework as defined in SFDR at the entity level.

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