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SFDR Disclosures


ESG Policy
Remuneration
Adverse Impact Statement


ESG Policy (Extract)

Introduction

Victory believes that on a global scale everyone has a responsibility to be conscious of ESG (environmental, social and governance) matters. We believe that appropriate consideration of ESG factors is part of a sound investment program and that incorporating ESG information into our decision making enables us to better understand and assess the investments we make and to positively impact ESG matters where possible. Our ESG commitments are overseen by the Board and managed by Ben Cooper (Executive Director), who is responsible for ESG within the firm and is responsible for enacting our ESG commitments in our day-to-day work as well as recording our ESG progress, reporting and recording.

Approach

Victory's approach to responsible investment is designed to more than just meeting industry best practices. Victory believes that the approach adopted is appropriate in light of the company's specific investment activities. This policy has been informed by consulting the United Nations Global Compact and the United Nations Principles for Responsible Investment of which Victory is in the process of becoming a signatory.

Furthermore, Victory will remain informed about ESG developments within relevant industries and the countries in which it operates. It will actively seek to optimise the sustainable performance of the company and the investments where it is possible to do so whilst still observing its fiduciary responsibility to investors to optimise financial returns. ESG issues are considered in specific asset underwriting, as part of our annual strategy meetings, as well as being reviewed on weekly investment committees and company meetings as required.

Victory understands its ESG responsibilities extend further than the company or its investments. As such, where practical, we will seek to review the ESG performance of contracted parties and suppliers as part of the selection and management process within the relevant part of a project / investment.

Victory Foundation

As well as the various points and examples set out below, Victory has also taken steps to set up the Victory Foundation. This foundation has been set up with ESG in mind and looks to add to Victory's overall contributions to ESG matters - in some cases these may be related directly with the investments (e.g. helping to fund the provision of emergency defibrillators to the benefit of a local community around an asset), whilst others are related to more overarching goals of Victory (e.g. funding sporting achievements for participants who would otherwise be unable to compete).

For further information, please download the Victory ESG policy.


Remuneration

The consideration of ESG risks by employees is important in the advancement of a career at Victory. Victory is keen to ensure that all employees are fully aligned with the Victory ESG Policy and adherence to such policy will be considered in every individual’s performance assessments. Such performance assessments will be linked to and impact the remuneration of employees.


Adverse Impacts of Investment Decisions on Sustainability Factors

Victory do not currently consider the adverse impacts of investment decisions on sustainability factors within the meaning of the SFDR. While ESG considerations are integrated into Victory’s investment process as outlined in the ESG policy the detailed rules underlying the SFDR will require Victory to ascertain the availability of the data expected to be reported under the new requirements of the SFDR. As such, the position will continue to be monitored and reviewed by Victory as the underlying rules are finalised.