PROSPERGATE CAPITAL LTD, is a company registered under the laws of the Republic of Cyprus, with registration number C369583. It is a regulated Cyprus Investment Firm (‘CIF’) by the Cyprus Securities and Exchange Commission (‘CySEC’) under license number 361/18. The Company is also acting as the External Manager of PROSPERGATE FUND AILFNP V.C.I.C LTD under the Small Alternative Investment Fund Managers Law of 2020 (L. 81(I)/2020).

The registered office of the Company is situated at 2 Filiou Zannetou street, 3021 Limassol Cyprus.

The Sustainable Finance Disclosure Regulation (EU) 2019/2088 (” SFDR” or “Regulation”) effective from 10 March 2021, was introduced by the European Commission as part of the Action Plan on Sustainable Finance. Under SFDR, Cypriot firms and fund managers, as well as other financial market participants in the European Union, are required to disclose specific information related to sustainability risks and impacts, with the aim of increasing transparency in the market and encouraging sustainable investment practices.

The purpose of this document is to address SFDR Article 3 on transparency of sustainability risk policies which states that: “Financial market participants shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision‐making process.”

At Prospergate Capital Ltd, we do not offer funds that seek to promote one or more environmental or social characteristics, nor do we have sustainable investment as our objective. 

However, as a financial market participant, we comply with the Sustainable Finance Disclosure Regulation (SFDR) to ensure that we transparently disclose our sustainability risk policies and how they are applied across our investment products.

Within the Policy, the Company aims to:

1. set the framework for the manner in which sustainability risks are integrated into their investment decisions, and
2. describe the approach taken to manage and monitor sustainability risks which may have a material influence on the funds managed by the Company.

The Company’s approach in integrating sustainability risks into its investment decision making process is to ensure that the services provided, and its operations do not result in unacceptable impacts on the environment and society.

This Policy describes the Company’s approach when handling and monitoring sustainability risks which may arise during the investment decision making process relating to the funds under management and fall under the scope of SFDR.

Sustainability risks form part of the investment risk management framework, which are taken into consideration along with other risk factors as part of the wider investment decision making process.

Following risk mitigation and due diligence measures taken, the Company considers that current sustainability risks on the investment portfolios are of a lower risk and the impact of such risks on investment returns is not considered as material.

If, however, in the future sustainability risks identified may have a material and negative impact on the returns of the fund/s, relevant risk mitigation strategies will be put in place.

According to Article 2 (22) of the Regulation, sustainability risks refer to environmental, social, and governance (ESG) factors that could have a material impact on the financial performance of an investment. These risks include:

• Environmental Risks: Such as climate change, natural resource depletion, water scarcity, pollution, and biodiversity loss.
• Social Risks: Including labour practices, human rights violations, product safety, community relations, and supply chain ethics.
• Governance Risks: Relating to issues like corporate governance practices, executive compensation, board composition, and shareholder rights.

Sustainability risks can have both short-term and long-term effects on the value of investments, and as such, should be considered as part of the Company’s investment decisions, even if the fund/s under management do not have a specific ESG focus.

At Prospergate Capital Ltd, we integrate sustainability risks into our investment decision-making through the following processes:

• Identification of Sustainability Risks: The Company identifies and assesses sustainability risks that may arise when making investment decisions.
• Due Diligence & Risk Management: We incorporate ESG factors into our overall risk management framework. Each investment is analysed for potential exposure to environmental, social, and governance risks that may impact its long-term financial performance. 
• Continuous Monitoring: We continuously monitor the sustainability risks associated with our investments, ensuring that any changes the regulatory landscape are reflected in our risk assessment models. 

As set out in Article 5 of the Regulation, a financial market participant (such as Prospergate) is required to include in its remuneration policy information on the integration of sustainability risks and how the remuneration structure is consistent with the integration of sustainability risks.

The Company, in its Remuneration Policy, promotes sound and effective risk management and is consistent with the objectives of the Company’s business and risk strategy, corporate culture and values, risk culture including with regard to environmental, social and governance (ESG) risk factors, long term interests of the Company and the measures used to avoid conflicts of interest and discourages excessive risk-taking on behalf of the Company.

The current Remuneration Policy of the Company is designed to support Prospergate’s strategic business objectives and core values in an appropriate risk controlled manner, by providing the remuneration mechanisms for Prospergate to attract, retain and motivate its colleagues in a manner that is consistent with the expectations of the Remuneration Requirements.

Further to the above, the Remuneration Policy also states that the performance management process (and therefore the remuneration arrangements) will also integrate non-financial methodologies in order to promote sound and effective risk management with respect to sustainability risks. This ensures that the Company’s remuneration structure will not encourage excessive risk‐taking with respect to sustainability risks and will be linked to risk‐ adjusted performance.

In order to achieve this, all employees of the Company will be expected to support the business in undertaking its activities in a responsible manner through the inclusion of sustainability considerations in their roles and in their decision-making process.

As part of our sustainability risk management framework, we actively consider the Principal Adverse Impacts (PAI) of our investments on sustainability factors including environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

The investment products we offer are non-ESG focused, with an emphasis on traditional financial performance factors, such as returns, liquidity, and risk management. Our funds are structured to follow standard market practices and are not designed to incorporate sustainability risks or ESG factors.

The Company does not consider any adverse impacts of its investment decisions on sustainability factors in respect of the fund/s under management as the investment strategies of the fund/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 Company will consider the principal adverse impacts of its investment decisions on sustainability factors.

We are committed to transparent communication regarding sustainability risks. Our policy includes:

• Regular Disclosure: When applicable we provide annual updates to investors on how sustainability risks have affected the financial performance of their investments.
• Pre-contractual and Ongoing Disclosures: As per SFDR, where applicable, we disclose sustainability risks in our pre-contractual documents and product disclosures. This information is updated regularly to reflect any material changes.

As the Company does not offer ESG-focused funds we are not required to provide product-specific disclosures about how our products meet environmental or social characteristics (Article 8) or sustainable investment objectives (Article 9). We will, however, meet the basic transparency obligations, such as disclosing sustainability risk integration, and other general considerations.

When the Company identifies types of conflicts of interest the existence of which may damage the interests of a fund/s, including conflicts of interest that may arise as a result of the integration of sustainability risks in the Company’s processes, systems and internal controls and conflicts of interest that could give rise to mis-selling or misrepresentation of investment strategies relevant actions will be taken to manage and prevent such conflicts. However, it should be noted that no conflicts of interest arise in terms of sustainability risks.

The Company will monitor and review this Policy on an annual basis and may be updated and changed from time to time in order to comply with any new legal requirements and/or amendments.
The Policy will be acknowledged by the Board of Directors of the Company after every review and/or material changes to its content.

If you would like to contact us with any queries or comments, please send an email to [email protected]

Prospergate Capital Ltd is a Cyprus Investment Firm (CIF) that is authorized by the Cyprus Securities and Exchange Commission (CySEC) (License number 361/18), with the license to perform portfolio management services. The company externally manages, on a discretionary basis, client funds that are located in global financial institutions pursuant to a pre-defined investment strategy. Since the risk of investing in certain financial instruments is generally high and the market value of such financial instruments may be exposed to varying factors, such as a turbulent economic and political environment, fluctuations in foreign exchange rates and shifts in market sentiment, the investor takes full responsibility for the risk involved with such investments and understands and acknowledges that investment yield and or capital preservation is not guaranteed. The investor should ensure that they are fully aware of the potential risks connected with Portfolio Management services and with their chosen investment strategy. The investor should be aware of the fact that some investment strategies may involve a higher degree of risk compared to other strategies and investments within this framework which may result in the loss of all or part of the initial investment. The investor should also understand and acknowledge that past performance does not guarantee future returns. Past performance should not be taken as an indication or guarantee of future performance.