Webster Equity Partners, LLC (“Webster”) makes the following disclosures in accordance with Articles 6(1) and 7(2) of the Sustainable Finance Disclosure Regulation (EU/2019/2088) (the “SFDR”).

Integration of sustainability risks

A sustainability risk means “an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment.” In the context of Webster, sustainability risks are risks which, if they were to crystallize, would cause a material negative impact on the value of the portfolios of Webster’s funds.

Webster’s policy on the integration of sustainability risks in its investment decision making process can be found in its Responsible Investment Policy (RI Policy), which follows a risk-management approach. The RI Policy defines sustainability risk as “ESG risk, which, if present, could either carry a high reputational risk, or is likely to have an impact on the financial condition or operating performance of [Webster] as an ongoing business.” Further information on how sustainability risks are integrated into investment decisions can be found in the RI Policy, which is available to investors upon request.

Webster will follow its procedures to identify and mitigate sustainability risks, although there can be no guarantee that Webster will successfully identify and mitigate all material risks.

No consideration of sustainability adverse impacts

Webster does not consider the principal adverse impacts of its investment decisions on sustainability factors (“the PAIs”) in the manner prescribed by Article 4 of the SFDR. This is because Webster considers that it is currently not able to obtain and/or measure all the data which would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost with respect to all investment strategies and decisions. This is in part because underlying investments are not widely required to, and may not currently, report by reference to the same data.

In practice, depending on the investment strategy and product, Webster may consider a relevant and material sub-set of the PAIs listed in the SFDR, such as employee labor relations or sound governance structures like anti-corruption and/or anti-bribery matters. These are considered by means of its global policy on integration of environmental, social and governance risks and value creation opportunities into its investment process. For further information, please see our RI Policy.

EU criteria for environmentally sustainable economic activities

The investments underlying these financial products do not consider the EU criteria for environmentally sustainable economic activities.

Webster’s stance on this matter will be reviewed periodically by reference to market developments.

Remuneration policy

Webster pays staff a combination of fixed remuneration (salary) and variable remuneration (including, for example, bonus). Variable remuneration allocated to staff reflects both personal and firm performance. Compliance with Webster’s risk management policies and procedures and risk control measures (which relate to, among other types of risk, sustainability risks) are considered in assessing the level of an individual’s variable remuneration. The performance assessment criteria also consider quantitative measures that might, depending on the role and responsibilities of the staff member, include financial metrics which would be impacted by the crystallization of risks.