Disclosures pursuant to Articles 3, 4 and 5 of the EU Sustainable Finance Disclosure Regulation (2019/2088) (SFDR)

Sustainability-related disclosures

As Pearl Diver Capital LLP (“Pearl Diver”) manages an alternative investment fund, Pearl Diver Capital European Income Fund (the “Fund”) that has been registered for marketing under the Alternative Investment Fund Managers Directive (2011/61/EU) (the “AIFMD”) in one or more member states of the European Economic Area (“EEA”), the company is required by the Sustainable Finance Disclosure Regulation (Regulation 2019/2088) (the “SFDR”) to make certain disclosures on its website, including information about the company’s policies on the integration of sustainability risks into its investment decision-making processes; its approach to adverse sustainability impacts; and the consistency of its remuneration policies with the integration of sustainability risks. For these purposes, sustainability risk means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Integration of sustainability risks into the investment decision-making process

Pearl Diver believes that responsible investment as well as environmental, social and governance considerations are a part of risk management and ultimately influence the long term performance of the Fund’ investments. The company incorporates ESG issues into investment decision-making process.

No consideration of sustainability adverse impacts

Given the investment objective and policy of the Fund to invest in structured credit notes, it does not currently consider adverse impacts of investment decisions on sustainability factors. The decision whether to consider adverse impacts of investment decisions on sustainability factors will be reviewed periodically.

Pearl Diver Capital is a signatory to the UN-supported Principles for Responsible Investment (PRI)

The PRI is a global, collaborative network of investors established in 2006 in recognition of the increasing relevance of ESG issues within the investment process. The Principles set forth by the PRI are a set of best practices for incorporating ESG issues into investment decision-making where consistent with fiduciary responsibilities. As a signatory, Pearl Diver Capital commits to the following:

  1. We will incorporate ESG issues into investment analysis and decision-making processes.
  2. We will be active owners and incorporate ESG issues into our ownership practices.
  3. We will seek appropriate disclosure on ESG issues by the entities in which we invest.
  4. We will promote acceptance and implementation of the Principles within the investment industry.
  5. We will work together to enhance our effectiveness in implementing the Principles.
  6. We will each report on our activities and progress towards implementing the Principles.


Consistency of remuneration policies

Pearl Diver’s remuneration policy is consistent with its approach to the integration of sustainability risks into the investment decision making process. As sustainability risks are a type of financial risk, the company acknowledges that failure to consider such risks could have an adverse impact on the performance of investments and the performance the Fund. Pursuant to the company’s remuneration policy, each team member is paid a variable remuneration, an annual bonus based on their performance during the year and the performance of the investments that they have been involved in during the year. Performance review and compensation is linked to the individual’s performance in their role, as reflected in the overall performance of the funds being managed. Accordingly, to the extent that sustainability risks have an adverse impact on performance of the Fund, this is likely to be reflected in the overall level of variable remuneration awarded to staff.