Legal & Regulatory Contact Us

Nevastar Sustainability Policy Summary


A. Nevastar Commitment

To the extent possible, Nevastar adopts a sustainable approach in its daily activities and investment strategies, integrating sustainability risks.

A sustainability risk means an environmental, social or governance event or condition that, which if they occur have or may potentially have significant negative impacts on the assets, financial and earnings situation, or reputation of a supervised entity.

For Nevastar, taking into consideration sustainability risks means integrating ESG factors (as defined below) in its daily business for the benefit of its clients and overall, the financial system.

The ESG factors are the following:

  • Environmental
    • GHG Emissions
    • Carbon Footprint
    • GHG Intensity
    • Exposure to Companies in fossil fuel sector
    • Share of non-renewable energy
    • Energy consumption intensity
    • Adjustment to climate change
    • Protection of biodiversity
    • The sustainable use and protection of water and maritime resources
    • The transition to a circular economy, the avoidance of waste, and recycling
    • The avoidance and reduction of environmental pollution
    • The protection of healthy ecosystems
    • Sustainable land use
  • Social
    • Compliance with recognised labour standards (no child labour, forced labour or discrimination)
    • Compliance with employment safety and health protection
    • Appropriate remuneration, fair working conditions, diversity, training and development opportunities
    • Trade union rights and freedom of assembly
    • Guarantee of adequate product safety, including health protection
    • Application of the same requirements to entities in the supply chain
    • Inclusive projects and consideration of the interests of communities and social minorities.
    • The facilitation of whistle blowing
  • Governance
    • Tax honesty
    • Anti-corruption measures
    • Sustainability management by the board
    • Board Independence measures
    • Board remuneration based on sustainability criteria
    • Adequate audit procedures
    • Information disclosure
    • Shareholder rights guarantees
    • Diversity
    • Entrenchment measures
    • Employee rights guarantees
    • Data protection guarantees

Nevastar manages both undertakings for collective investments in transferable securities in accordance with the UCITS Law (the UCITS) and alternative investment funds in accordance with the AIFM Law (the AIFs).

In accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (SFDR), Nevastar identifies and analyses sustainability risks as part of its risk management process. To the extent possible, Nevastar adopts a sustainable approach in its daily activities and investment strategies, integrating sustainability risks.

Consequent impacts to the occurrence of sustainability risk can be many and varied according to a specific risk, region or asset class. Generally, when sustainability risk occurs for an asset, there will be a negative impact and potentially a total loss of its value and therefore an impact on the net asset value of the concerned fund.

Although Nevastar aims in all its investment strategies to integrate ESG factors, there are different levels of consideration given to sustainability risks depending on the strategy pursued which are further described in the pre-contractual documents of the funds in accordance with SFDR.

As of today, Nevastar is currently not in a position to consider principal adverse impacts of investment decisions on sustainability factors due to a lack of available and reliable data.


B. Our ESG products

Article 9 SFDR

Some of our products have sustainable investment as objective, and are in compliance with Article 9 of SFDR.As further described in the prospectus of such funds, the investment selection generally follow two steps:

  • Step 1: for at least 90% of the issuers, securities are excluded from the investment universe if they belong to a sector that has no link with the sustainable objective of the fund and if their activity is deemed unsustainable.
  • Step 2: an ESG score per security is defined based on information sourced from known ESG data providers. Based on the score determined for each of the ESG categories, a global ESG score is calculated at stock level by agglomerating the category scores , with a particular emphasis on the ESG factor corresponding to the sustainable objective of the fund.

Article 8 SFDR

Some of our products are promoting sustainable investment and are in compliance with Article 8 of SFDR.

As further described in the prospectus of such funds, the investment selection generally follow two steps:

  • Step 1: for at least 90% of the issuers, securities are excluded from the investment universe if they belong to a sector that has no link with the sustainable objective of the fund and if their activity is deemed unsustainable.
  • Step 2: an ESG score per security is defined based on information sourced from known ESG data providers. This score is one of the element used for the investment decision.

In order to achieve these objectives, relating both to fund compliant with article 9 and article 8 of SFDR, Nevastar relies on data services providers. It has to be noted that, as of the date of this policy, there is currently no standardization hence the data provided by these data services providers vary in terms of the underlying methodologies to interpret the collected non-financial information of companies and in terms of underlying data elements themselves that data providers use to calculate the ESG ratings/scores per company.

Therefore, from time to time, Nevastar will cross-check the data of its service provider(s) to ensure that no significant difference exist between the respective rating provided for the same company, failing which, Nevastar proceeds with further investigation.


C. Other products (article 6 SFDR)

Although sustainability risks are taken into account in all Nevastar activities, some UCITS and AIFs managed by Nevastar do not per se consider ESG factors in the investment selection. Nevastar has identified and analysed sustainability risks for each fund based on ESG factors. Further to said analysis, Nevastar is of the opinion that sustainability risks and potential impacts on current portfolio of certain funds is not significant and hence will not significantly impact their returns. Therefore, at this stage, Nevastar considers sustainability risks to be irrelevant for these funds as currently other factors considered in the stock picking process overweigh this risk.


D. Contacts

For further information concerning Nevastar sustainability approach, please contact us by email at risk@nevastar.lu.