SFDR

EU’s Sustainable Finance Disclosure Regulation
Statements made in accordance to applicable provisions under Articles 3, 4 and 5 of the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“Disclosure Regulation” or “SFDR”).

Integration of sustainability risks in investment decision‐making processes
Sustainability risks means an environmental, social or governance (ESG) event or condition that, if it occurs, could cause actual or potential material negative impact on the value of the investment. In line with the SFDR which entered into force on 10 March 2021, Brook Lane considers where material sustainability risks when selecting investments as part of the overall risk assessment of the Funds that Brook Lane externally manages.

Brook Lane acknowledges that when sustainability risks occur, there may be negative impact on an assets value and therefore this could have a material impact on the Net Asset Value of the Funds under management.

No consideration of sustainability adverse impact
Principal adverse impacts on sustainability factors refer to adverse impacts of investment decisions on sustainability factors that mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

In accordance with the discretion granted pursuant to the SFDR, Brook Lane does not consider the adverse impacts of investment decision on sustainability factors in respect of the Fund(s) under management as the Investment Strategies of the Funds(s) under management do not regard sustainability factors to be material to their investment strategy. In the event that sustainability factors do, in the future, become material, the Manager will consider the principal adverse impacts of its investment decisions on sustainability factors.

Remuneration policy and the integration of sustainability risks
Brook Lane does not encourage or reward an excessive assumption of sustainability risks according to its remuneration policy. The said policy is consistent with the integration of sustainability risks.

The information contained on this website is communicated by Brook Lane Capital Limited, a private company limited by shares registered in Cyprus with registration number HE 423124, having its registered office at 131 Athalassas str., 3rd floor, office 301, CY-2023, Nicosia, Cyprus. Brook Lane Capital Limited is authorised and regulated as an Alternative Investment Fund Manager (‘AIFM’) by the Cyprus Securities and Exchange Commission (‘CySEC’) with License Number AIFM57/56/2013”.

Website content.
The contents and information on the Website do not constitute a solicitation, offer or recommendation to purchase, or deal in any investment referred to on the Website, or otherwise engage in any related transactions. The information provided on the Website is for informational purposes only and should not be relied on for purposes of making an investment decision. Nothing on the Website should be construed as investment, legal, tax, regulatory or accounting advice and Prospective Investors should seek their own independent advice on all such matters.

The contents and information on the Website are not intended for distribution to, or use by, persons subject to a legal system prohibiting publication or access to the Website (including the United States) or where the investment funds and services referred to herein are not authorised or registered for distribution or in which the dissemination of information on the funds or services is forbidden. This disclaimer and any claims arising out of or in connection with the terms and conditions of this disclaimer are governed by the laws of Cyprus. The Company retains the right to deny Prospective Investors in any particular jurisdiction in order to conform to local law, customs or business practice or for anti-money laundering, fiscal or any other reasons.

Changes to website.
The information is subject to change without notice and that the investors agree to review these terms of use regularly and continued use of the website means they agree to any changes made.

Terms and Conditions.
Please refer to the Company’s Terms and Conditions.

Confidentiality/Privacy Policy.
All information contained is confidential and subject to copyright, including Personal Data provisions where these are applicable. Please refer also to the Company’s Privacy Policy.