SFDR Disclosure

These are our (“Goodwell Investments” “Goodwell” “us” “we” ) website disclosures in terms of 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 (SFDR).

We will publish and maintain information here about our policies dealing with how we integrate sustainability risk in our investment decision making process. Put simply: how and to what extent, in addition to financial risks, do we consider the negative impact of sustainability risks on financial returns.

These disclosures will also tell you where we do, or do not, consider adverse impacts of our decisions on sustainability factors. It will briefly describe our process for contextually considering adverse impacts, and reason(s) why in some cases we would not consider adverse impacts.  There may also be instances where we initially do not consider adverse impacts, but certain factors may result in our re-evaluation.

You will also find a description of the Goodwell V funds’ sustainable investment objectives, which show the methodologies or indices used to track our progress towards achieving the sustainable objective. If there is no applicable or useful benchmark index, then these disclosures will narratively provide information on how the investment objectives of the fund’s will be achieved.

Note, that we fall under the registration regime of the AIFM Directive 2011/61/EU and as such the  directive does not fully apply to us. Therefore, we are not required to make article 23 disclosures. Despite this we report extensively on ESG to our investors in our periodic reporting which will also include article 9 disclosures for our funds.

These disclosures also explain our remuneration policy.