Bluegem Capital (Luxembourg) S.à r.l

PAI Consideration Disclosure

OCTOBER 2024

Introduction

Bluegem Capital (Luxembourg) S.à r.l. (the “Company”) is a private limited liability company (société à responsabilité limitée) incorporated under the laws of the Grand Duchy of Luxembourg, having its registered office at 4-6, rue de la Boucherie, L-1247 Luxembourg, Grand Duchy of Luxembourg and registered with the Luxembourg Trade and Companies Register under number B283767.

The Company is authorised by the Commission de Surveillance du Secteur Financier (the “CSSF”) as an alternative investment fund manager within the meaning of chapter 2 of the Luxembourg Law of 12 July 2013 on alternative investment fund managers, as amended (the “AIFM Law”).

The Company is part of the same group as Bluegem Capital Partners LLP, located in the United Kingdom, together the “Bluegem Group”.

Purpose

Pursuant to EU Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR”), financial market participants shall publish on their websites information about how principal adverse impacts (PAI) of investment decisions on sustainability factors (“comply or explain”) are considered in the management of AIFs. 

PAI Statement Disclosure:

No consideration of sustainability adverse impacts.

Bluegem Capital (Luxembourg) S.à r.l. does not currently consider the adverse impacts of investment decisions on sustainability factors, mostly because the Company delegates the portfolio management function to Bluegem Capital Partners LLP, a suitably qualified and skilled investment manager (the “Investment Manager”). Therefore, “investment decisions” as defined under SFDR are delegated to the Investment Manager, subject to the Company’s ongoing oversight:

Bluegem Capital Partners LLP

Bluegem Capital Partners LLP (“Bluegem”), in its capacity as Investment Manager, does not consider the adverse impacts of its investment decisions on sustainability factors.

Whilst Bluegem supports the objectives of SFDR with respect to transparency of due diligence policies and reporting against relevant quantitative metrics in respect of portfolio investments, the Investment Manager has chosen not to consider these impacts at this time, predominantly due to the nature of its investment strategy and the limited capacity of the Investment Manager to materially engage with, and report on, these issues in a relevant and meaningful way.