SFDR – Sustainability-Related Disclosures

Leucadia Asset Management LLC (“we” and “LAM”) is a U.S. investment adviser, registered with the SEC, and serves as adviser or sub-adviser for various alternative investment funds (each, a “Fund”) some of which are marketed within the EU.

The disclosures below explain the details of how LAM complies with the disclosure requirements in accordance with the European Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”).

Policies on the Integration of Sustainability Risks

Under SFDR, “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 an investment. 

LAM has adopted an ESG policy which sets forth two levels of ESG engagement: (i) participation in broader ESG initiatives that are driven by how LAM manages the operations of its business and strives to integrate ESG considerations as a fundamental component of its business operations; and (ii) certain Fund strategies advised by LAM specifically incorporate ESG considerations as part of their investment strategy. The manner and extent in which LAM takes sustainability risks into consideration in its investment advice therefore varies from Fund to Fund and LAM does not take a harmonized approach to integrating sustainability risks across all of its Funds.

No consideration of adverse impacts of investment decisions on sustainability factors

SFDR requires firms to make a “comply or explain” decision whether to consider the Principal Adverse Impacts (“PAIs”) of its investment decisions on sustainability factors, in accordance with a specific regime as outlined in SFDR.  LAM has decided not to comply with the SFDR PAI regime at an entity level in relation to all of its investment decisions.  LAM is therefore required to publish and maintain on its website a statement to explain its reasons for not complying with the PAI regime in SFDR and information as to whether and, if so, when LAM intends to comply with the regime.

LAM has carefully evaluated the requirements of the SFDR PAI regime in light of the types of Funds that it makes available.  LAM notes that its investment strategies and client relationships do not support the consideration of the PAI across all of its investment decisions as the consideration of PAI will depend specifically on the investment strategy for a particular Fund.

LAM will keep its decision not to comply with the SFDR PAI regime under review and will formally re-evaluate the decision periodically.

Integration of Sustainability Risks in Remuneration Policies

As a non-EU AIFM, LAM does not have a remuneration policy for the purposes of AIFMD. Accordingly, LAM does not disclose how is remuneration policy is consistent with the integration of sustainability risks for the purposes of Article 5 of SFDR.