Sustainability related disclosures

BlueBay Funds Management Company SA and BlueBay Asset Management LLP (“BlueBay”) are required to comply with the requirements set out under the EU Sustainable Finance Disclosure Regulation (“SFDR”) as Financial Market Participants (“FMPs”) and a Financial Adviser. BlueBay Asset Management LLP is categorised as an FMP to the extent that it distributes products to EU investors. The information disclosed herein outlines BlueBay’s compliance with the requirements under SFDR.

Relevance of Sustainability Risks to the returns of our products and policies on the integration of Sustainability Risks in the investment decision-making process

BlueBay considers Sustainability Risks to be relevant to the returns of the products we manage and has a policy to integrate Sustainability Risks into our investment decisions.

Since 2013, BlueBay has had an Environmental, Social and Governance (ESG) investment management framework in place firmwide to incorporate ESG factors and risks into its investment decisions. This Environmental, Social and Governance (ESG) Investment Policy outlines the approach we take to incorporating ESG considerations within our investment management practices at BlueBay. This Policy sets out our approach to ESG factors and ESG risks, how these considerations fit within our investment philosophy, our approach to the investment strategies we manage, how we resource and manage this from a governance perspective, as well as how we communicate our efforts and progress. It applies as standard to all investments made within pooled funds (“Funds”), separately managed accounts (“SMAs”) and where BlueBay provides investment advice.

The information in the Environmental, Social and Governance (ESG) Investment Policy outlines BlueBay’s compliance with the requirements under SFDR to disclose BlueBay’s approach to integrating ESG, and therefore Sustainability Risks into our decision-making. Please note that all references to ‘ESG risks’ and ‘ESG factors’ within this Policy are equivalent to ‘Sustainability Risks’ and ‘Sustainability Factors’ as defined in SFDR. Sustainability risks are deemed by BlueBay as being relevant to the returns of its products. Accordingly, all BlueBay managed assets (Funds and SMAs) integrate Sustainability Risks into the investment decision making process and this has been detailed in this Policy.

Environmental, Social and Governance (ESG) Investment Policy (BlueBay Asset Management LLP)

Environmental, Social and Governance (ESG) Investment Policy (BlueBay Funds Management Company S.A.)

Remuneration Policy and Sustainability Risks

The policies below include information on the integration of Sustainability Risks into remuneration practices.

BlueBay Asset Management Group Remuneration Policy

BlueBay Funds Management Company S.A. Remuneration Policy

Consideration of Sustainability Adverse Impacts

BlueBay Asset Management and BlueBay Funds Management Company S.A (‘BlueBay’) do not meet the criteria set out in Article 4 of the EU Sustainable Finance Disclosure Regulation (‘SFDR’).  However, effective August 2022,  BlueBay has chosen to voluntarily comply and considers the principal adverse impacts (‘PAIs’) of its investment decisions on sustainability factors.  As such, in the context of SFDR, BlueBay has also issued a ‘Principal Adverse Impacts Statement’ with respect to the principal adverse impacts of its investment decisions on Sustainability Factors.

BlueBay Asset Management Group Principal Adverse Impacts Statement

SFDR Product Categorisation

All products managed by BlueBay that fall within the scope of SFDR meet the conditions set out in Article 6 of SFDR as Sustainability Risks are integrated into the investment decision making process.

The table lists those in scope products which meet Article 8 (in promoting environmental or social characteristics and follows good governance practices) or Article 9 (with sustainable investment as its investment objective) under SFDR. All other in scope BlueBay Funds meet the conditions set out in Article 6 of SFDR as Sustainability Risks are integrated into the investment decision making process.