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Disclaimer

ESG Principal Adverse Impacts StatementESGPrincipalAdverseImpactsStatement

Mar 10, 2021

Statement

PGIM PRIVATE CAPITAL (IRELAND) LIMITED
Explanation of non-compliance with SFDR’s principal adverse impacts regime

10 March 2021

 

This document sets out disclosures by PGIM Private Capital (Ireland) Limited (the “Firm”), in respect of the principal adverse impacts of our investment decisions on sustainability factors.  

The EU Sustainable Finance Disclosure Regulation (“SFDR”) requires the Firm to make a “comply or explain” decision whether to consider the principal adverse impacts (“PAIs”) of our investment decisions on sustainability factors, in accordance with a specific regime as outlined in SFDR. The Firm has decided not to comply with that SFDR regime. The firm is therefore required to publish and maintain on our website a statement to explain our reasons for not complying with the PAI regime in SFDR, and information as to whether and when we intend to comply with such regime.

Non-compliance with the PAI regime in SFDR

  1. The Firm has carefully evaluated the requirements of the PAI regime in Article 4 SFDR, and in the draft Regulatory Technical Standards which were published in April 2020 (the “PAI regime”).  
  2. The Firm is supportive of the policy aims of the PAI regime, to improve transparency to clients, investors and the market, as to how financial market participants integrate consideration of the adverse impacts of their investment decisions on sustainability factors.  However, taking account of the nature and scope of our activities, we have elected not to comply with the regime at this time. 
  3. The Firm is also concerned about the lack of readily available data to comply with the technical reporting requirements of the PAI regime. We are an active investor in private enterprises for which limited public data exists. Many private enterprises do not currently track such data. Furthermore, given the large number of complex metrics set out in the technical reporting requirements of the PAI regime, we believe many small and medium sized enterprises are unlikely to be able to produce such data in a cost-effective manner. 
  4. The Firm will keep its decision not to comply with the PAI regime under regular review. 
  5. Notwithstanding our decision not to comply with the PAI regime, the Firm also wishes to re-affirm our overall commitment to ESG matters.  Please see a summary of our firm’s Sustainability Risks Policy available on our website at: www.pgimprivatecapital.com.   Under this policy, the firm has integrated consideration of ESG issues into our investment processes.
     
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SFDR Renumeration Policyopens in a new window       ESG Principal Adverse Impacts Statementopens in a new window

For Professional Investors only. All investments involve risk, including the possible loss of capital.

This material is for informational and educational purposes only and should not be construed as investment advice or an offer or solicitation in respect of any products or services to any persons who are prohibited from receiving such information under the laws applicable to their place of citizenship, domicile or residence. PGIM, Inc., is the principal asset management business of Prudential Financial, Inc. (“PFI”) and is a registered investment advisor with the US Securities and Exchange Commission. Registration with the SEC does not imply a certain level of skill or training.  PGIM is a trading name of PGIM, Inc and its global subsidiaries. PGIM Private Capital is a trading name of PGIM, Inc.  and it is also a trading name of PGIM Private Capital Limited and PGIM Private Capital (Ireland) Limited. 

In the United Kingdom information is issued by PGIM Private Capital Limited, an indirect subsidiary of PGIM, Inc, with registered office: Grand Buildings, 1-3 Strand, Trafalgar Square, London, WC2N 5HR.  PGIM Private Capital Limited  is authorised and regulated by the Financial Conduct Authority of the United Kingdom (Firm Reference Number 172071) and registered in England No. 1331817. In the European Economic Area (“EEA”), information is issued by PGIM Private Capital (Ireland) Limited with registered office: Pramerica Drive, Letterkenny Business and Technology Park, Letterkenny, Co Donegal, F92 W8CY, Ireland. PGIM Private Capital (Ireland) Limited is authorised and regulated by the Central Bank of Ireland and registered in Ireland under company number 635793 operating on the basis of a European passport. In certain EEA countries, information is, where permitted, presented by PGIM Private Capital Limited in reliance of provisions, exemptions or licenses available to PGIM Private Capital Limited. This information is intended only for persons who are professional clients or eligible counterparties for the purposes of the Financial Conduct Authority’s Conduct of Business and/or to persons who are professional clients as defined in the relevant local implementation of Directive 2014/65/EU (MiFID II). 

In Japan, investment management services are made available by PGIM Japan, Co. Ltd., ("PGIM Japan"), a registered Financial Instruments Business Operator with the Financial Services Agency of Japan. In Hong Kong, information is presented by representatives of PGIM (Hong Kong) Limited, a regulated entity with the Securities and Futures Commission in Hong Kong to professional investors as defined in Part 1 of Schedule 1 of the Securities and Futures Ordinance. In Singapore, information is issued by PGIM (Singapore) Pte. Ltd. ("PGIM Singapore"), a Singapore investment manager that is licensed as a capital markets service license holder by the Monetary Authority of Singapore and an exempt financial adviser. These materials are issued by PGIM Singapore for the general information of "institutional investors" pursuant to Section 304 of the Securities and Futures Act, Chapter 289 of Singapore (the "SFA") and "accredited investors" and other relevant persons in accordance with the conditions specified in Sections 305 of the SFA. In South Korea, information is issued by PGIM, Inc., which is licensed to provide discretionary investment management services directly to South Korean qualified institutional investors. In Canada, pursuant to the international adviser registration exemption in National Instrument 31-103, PGIM, Inc. is informing you that: (1) PGIM, Inc. is not registered in Canada and is advising you in reliance upon an exemption from the adviser registration requirement under National Instrument 31-103; (2) PGIM, Inc.’s jurisdiction of residence is New Jersey, U.S.A.; (3) there may be difficulty enforcing legal rights against PGIM, Inc. because it is resident outside of Canada and all or substantially all of its assets may be situated outside of Canada; and (4) the name and address of the agent for service of process of PGIM, Inc. in the applicable Provinces of Canada are as follows: in Québec: Borden Ladner Gervais LLP, 1000 de La Gauchetière Street West, Suite 900 Montréal, QC H3B 5H4; in British Columbia: Borden Ladner Gervais LLP, 1200 Waterfront Centre, 200 Burrard Street, Vancouver, BC V7X 1T2; in Ontario: Borden Ladner Gervais LLP, 22 Adelaide Street West, Suite 3400, Toronto, ON M5H 4E3; in Nova Scotia: Cox & Palmer, Q.C., 1100 Purdy’s Wharf Tower One, 1959 Upper Water Street, P.O. Box 2380 - Stn Central RPO, Halifax, NS B3J 3E5; in Alberta: Borden Ladner Gervais LLP, 530 Third Avenue S.W., Calgary, AB T2P R3.

PFI of the United States is not affiliated in any manner with Prudential plc, incorporated in the United Kingdom or with Prudential Assurance Company, a subsidiary of M&G plc, incorporated in the United Kingdom. 

PGIM, the PGIM logo and Rock design are service marks of PFI and its related entities, registered in many jurisdictions worldwide.

The information on this website is not intended as investment advice and is not a recommendation about managing or investing your retirement savings. In making the information available on this website, PGIM, Inc. and its affiliates are not acting as your fiduciary.

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