Integration of sustainability risks into the investment decision process

Application: The firm named, SBL Capital Luxembourg, managing the fund European Secured Bridge Financing 1 (ESBF-1), falls within the scope of SFDR and have been categorised as Article 6 products
Last Update: June 2025

The following process is applied in order to integrate sustainability risks into the investment decision process of the Article 6 product: ESBF-1
The prospective borrower, being the counterparty to a portfolio investment of an AIF, is not permitted to operate in certain sectors, deemed unethical, such as arms manufacturing, gambling, tax avoidance, businesses with poor employment practices, businesses associated with human rights abuse or oppressive regimes, the sex industry, and petrol stations.
As such, the AIFM is bound to take investment decisions according to the borrower’s eligibility subject to the Negative Screening.
Where relevant SBL’s ESG Committee will be requested to provide advice to the AIFMs Investment Committee in relation to this Negative Screening process.
In addition, SBL will consider, where requested by a client, try to include additional screening into the investment process.
SBL also encourages its portfolio companies to implement ESG guidelines and processes and have introduced financial incentives for borrowers to further strengthen their commitments to ESG.
Principal Adverse Impacts – Neither the entity nor the fund do consider the principal adverse impacts.
Integration of sustainability risks into the remuneration policy
SBL aims to promote a sound and effective risk management with respect to sustainability risks.
As such it ensures that the approach to remuneration does not encourage excessive risk and achieves a balance between sustainability risks and risk-adjusted performance.
More precisely, the SBL’s approach to remuneration of investment professionals and other senior executives is to align the manager’s incentives with asset owners’ long-term interests and the long-term success of the investment management company.
In addition, the SBL’s approach is to promote a sound and effective risk management culture that will protect the value of the investment portfolio.
As such, the integration of ESG risk considerations within the investment process is used as an instrument to enhance investment performance, which would equally benefit the clients, the asset management firm and its employees.

SFRD Article 6