Disclosure regulation

AltamarCAM integrates sustainability risks into its investment decisions and investment advice

Altamar Private Equity, S.G.I.I.C., S.A.U., CAM Alternatives GmbH and Altan Capital, S.G.I.I.C., S.A.U. (hereinafter and jointly, “AltamarCAM”1) are subject to the Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector, (hereinafter “SFDR” or the “Regulation”).

AltamarCAM integrates sustainability risks into its investment decisions and investment advice. To enhance transparency and inform end investors, the policies on the integration of these risks, as required by Article 3 of the SFDR, are included in the ESG Policy.

The Remuneration Policy2 includes information on how the remuneration system is consistent with the integration of sustainability risks, as established in Article 5 of the Regulation.

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

Altamar Private Equity, S.G.I.I.C., S.A.U., CAM Alternatives GmbH and Altan Capital, S.G.I.I.C., S.A.U. (henceforth and combined, “AltamarCAM”) do not consider nowadays adverse impacts of investment decisions and investment advice on sustainability factors, in the manner prescribed by Article 4 of the SFDR.

The nature of the vehicles managed by AltamarCAM (mainly fund of funds) implies that to consider adverse sustainability impacts, AltamarCAM should receive from the managers of the underlying funds the mandatory information in order to comply with the regulation, currently being principal adverse impacts not available to all underlying managers (in the way these indicators are formulated in the Annex I of Commission Delegated Regulation (EU) 2022/1288).

AltamarCAM takes sustainability and ESG very seriously, using its own procedures, policies and metrics to assess the adverse impacts of investment decisions on sustainability factors not-aligned with those prescribed under Article 4 of the SFDR and the Annex I of Commission Delegated Regulation (EU) 2022/1288, as AltamarCAM considers that these are more appropriate and tailored to AltamarCAM and the investments that AltamarCAM makes on behalf of its funds, and therefore assist in AltamarCAM’s objective to deliver long-term risk-adjusted returns to investors.

AltamarCAM expects to keep this position under review by reference to applicable market developments and future availability of information, and then, consider the adverse impacts of both the investment decisions and the investment advice on sustainability factors.

Disclosure in relation to the products that are subject to Article 8 or Article 9 of the Sustainability Disclosures Regulation

AltamarCAM publishes and maintains the information required under Article 10 of the SFDR for each of the Funds in scope of Article 8 or Article 9 of the SFDR available in the following links:

 Date of last review: September 2022

[1] With the corresponding LEI numbers as follows: Altamar Private Equity, S.G.I.I.C. S.A.U. = 959800JVK9H8P0W46002; CAM Alternatives GmbH = 5299009ZLS4BUQ8SBE38; and Altan Capital, S.G.I.I.C., S.A.U. = 959800EMHCGTUV184V41

[2] Currently, Altamar Capital Partners, S.L. (together with its subsidiaries) and CAM Alternatives GmbH have independent remuneration policies.

[3] Sustainability adverse impacts: negative material or likely to be material effects on sustainability factors that investment decisions and advice might cause, contribute to, or be directly linked to.