At Akiles, we see responsible investing as a way to create long-term value—not just for our investors, but for businesses and society as a whole. While we are not classified as a sustainable investment fund under the EU's Sustainable Finance Disclosure Regulation (SFDR), we recognize the importance of Environmental, Social, and Governance (ESG) factors in long-term value creation.
Our Approach to ESG
While we do not have a formal ESG rating system, we make sure the businesses we support align with responsible business practices and good governance. We look at ESG risks when assessing investment opportunities, but we do not formally track the negative ESG impacts of our investments under SFDR. Instead, we take a case-by-case approach, ensuring that our investments don’t contribute negatively to society or the environment.
Rather than applying strict ESG labels, we integrate ESG principles in a way that makes sense for our business. We:
- Avoid investing in industries that cause significant harm to people or the planet.
- Support companies that demonstrate strong governance, transparency, and ethical decision-making.
- Encourage the businesses we work with to adopt responsible ESG practices over time.
We understand that ESG is an evolving space, and we are open to adapting our policies as needed. Our goal is to balance responsible investing with practical decision-making that benefits our investors and the businesses we support.
ESG Disclosure in accordance with SFDR
Akiles Management - March 2025
In its capacity as a sub-threshold alternative investment fund manager ("AIFM"), Akiles Management (the "Manager") is subject to disclosure obligations relating to environmental, social, and governance ("ESG") matters as set forth in:
- Regulation (EU) No. 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector ("SFDR");
- Commission Delegated Regulation (EU) 2022/1288 supplementing Regulation (EU) 2019/2088 regarding regulatory technical standards ("RTS");
- Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment ("Taxonomy Regulation").
The Manager may update this information periodically and will publish any amendments on its website.
1. Integration of Sustainability Risks
The Manager acknowledges that ESG-related risks can have an impact on the performance of investment portfolios. However, Akiles Management does not formally integrate sustainability risks into its investment decision-making process as referred to in Article 3 of the SFDR. While sustainability risks are considered in the broader investment assessment, they are not formally quantified or assessed for their potential financial impact on investment returns.
2. No Consideration of Adverse Sustainability Impacts
In accordance with Article 4(1)(b) of the SFDR, Akiles Management does not consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors. The decision not to consider PAIs is based on the following factors:
- The investment strategy of Akiles Management focuses on small and medium-sized enterprises (SMEs), which often lack the data required to comprehensively assess adverse sustainability impacts.
- Given the size and operational capacity of Akiles Management, implementing a systematic approach to measuring adverse impacts would impose a disproportionate administrative burden.
At this time, Akiles Management does not intend to adopt the consideration of adverse sustainability impacts as defined in Article 4(1)(a) of the SFDR but will continue to monitor regulatory developments and industry best practices.
3. ESG Commitment and Investment Approach
Akiles Management recognizes the importance of responsible investing and seeks to align with the broader principles of sustainability. While it does not promote environmental or social characteristics as defined under Article 8 SFDR, nor does it have a sustainable investment objective under Article 9 SFDR, the Manager actively considers ESG factors as part of its qualitative assessment of investment opportunities.
Akiles Management invests in companies that demonstrate responsible business practices, governance, and a commitment to long-term value creation for all stakeholders. The Manager does not invest in businesses that engage in activities that could significantly harm environmental or social factors.
4. Sustainability Risks in Remuneration Policies
As a sub-threshold AIFM, Akiles Management is not subject to formal remuneration policy requirements under Article 40 of the Belgian Law of 19 April 2014 on alternative investment entities and their managers. Consequently, sustainability risks are not formally integrated into its remuneration policies.
5. Future Considerations
Akiles Management reste engagé à améliorer en permanence ses pratiques ESG.
Akiles Management remains committed to continuously improving its ESG practices. As regulatory requirements evolve and data availability improves, the Manager may reassess its approach to integrating sustainability risks and considering adverse sustainability impacts.
For further information, please contact us at info@akiles.be.