As of 10 March 2021, the EU's Sustainable Finance Disclosure Regulation (the “SFDR”) has come into force, representing an important step in progressing the EU’s Sustainable Finance Action Plan to mobilise investment for sustainable growth.

The regulation requires fund managers like Tiny Supercomputer Management Company (UK) Ltd (”TSMC”) as an authorised AIFM to provide sustainability-related disclosures on our website and in our product documentation.

Please refer to the disclosures below.

No consideration of adverse impacts of investment decisions on sustainability factors

Sustainability risk is defined in the SFDR as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

TSMC considers sustainability risks in the general course of its due diligence of prospective investments, its risk management processes and the ongoing monitoring of its portfolio. The sustainability risks that may cause an actual or potential negative impact on the value of our investment funds’ investments include environmental, social and governance risks, eg.:

• Environmental: risks related to high energy consumption; lack of energy efficiency; and/or high waste production.
• Social: risks related to lack of respect for fundamental employee rights, lack of diversity, incidents of discrimination; and/or lack of diversity, incidents of discrimination; and/or lack of grievance handling mechanisms at the level of our portfolio companies;
• Governance: risks due to lack of institutionalised governance structures; transparency and functions control; and/or appropriate policies and processes ensuring sound governance at the level of our portfolio companies.

TSMC considers that the likely impact of these sustainability risks on the returns of its investment funds are, if any, low.

TSMC does not currently consider the adverse impacts of its investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFDR, as the relevant data is not yet available in the market to a sufficient extent.

TSMC may consider amending its investment process to consider the principal adverse impacts of investment decisions on sustainability factors within the meaning of and in the manner prescribed by the SFDR in due course. As investors' requirements, legislation, global climate and resource challenges evolve, TSMC’s approach to sustainability and ‘future-proofing’ continues to develop.

Remuneration policy in relation to the integration of sustainability risks

TSMC’s Remuneration Policy promotes sound and effective risk management with respect to sustainability risks, ensuring that the structure of remuneration does not encourage excessive risk-taking with respect to sustainability risks.

TSMC also considers the effect of potential conflicts of interest on remuneration in a way that is consistent with the integration of sustainability risk, including (but not limited to), any activities that give rise to greenwashing, mis-selling, or misrepresentation of investment strategies.

Integration of sustainability risk management in investment process

TSMC considers sustainability risks in the course of its general due diligence of prospective investments, its risk management processes and the ongoing monitoring of its portfolio.

Being a ‘good citizen’ remains at the core of TSMC’s ethos and values, and we will continue to uphold and advocate socially accountable standards for ourselves, our investment prospects and our growing portfolio.

Last updated August 2024