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Our Sustainability Risks
Integration Policy

Statement about the integration of sustainability risks in investment and portfolio
monitoring activities and transparency of remuneration policies in relation to the
integration of sustainability risks.

Pursuant to Article 3 and Article 5 of 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 (Disclosure Regulation or SFDR).

1. Purpose

Iron Wolf Capital integrates relevant sustainability risks in all aspects of its investment
strategies, client solutions, and organization.

A sustainability risk is an environmental, social, or governance (ESG) event or situation that, if it occurs, could have an actual or potential material adverse impact on the value of an

The purpose of this policy is to define the framework by which Iron Wolf Capital will manage
sustainability risks in its business activities. This policy aims to foster an operating culture
that promotes sustainable and ethical behavior in conducting Iron Wolf Capital’s own business.

It also aims at making sure that Iron Wolf Capital’s investment products are protected from or
can cope with material sustainability risks that might have a negative effect on the environment, society, performance, or reputation.

2. Scope

The sustainability risks integration policy applies to the management of Iron Wolf Capital and to the investment products that are managed by Iron Wolf Capital. It includes all of Iron Wolf Capital’s business operations and investment decision-making processes that are under its control.

3. SRI Into Investment Decisions

Sustainability risk considerations are integrated into our investment decision framework as part of the overall risk assessment.

The stages at which sustainability risks are integrated into the investment decision-making
process occurs at the following stages:

  • Term sheet and Legal Documents

  • Ownership and Monitoring


How sustainability risk considerations are integrated into practices might differ among our
investment teams as the relevance, availability of information, and time horizon of sustainability risks will vary depending on the investment product’s characteristics.

4. Sustainability Risks Assessment Approach

Iron Wolf Capital assesses, integrates, and manages the likely impacts of sustainability risks on financial returns. Sustainability factors cover a broad range of issues, including (but not limited to):

  • Environmental factors: climate change vulnerability, carbon pricing, biodiversity, water, waste management, pollution, etc.

  • Social factors: compliance with recognized labor standards, compliance with employment safety and health protection, fair working conditions, diversity, and development opportunities, product safety and customer welfare, infectious diseases, etc.

  • Governance factors: risk and business continuity management, integrity, and ethical behavior, information security and data protection, board composition and remuneration, regulatory and tax compliance, political instability, etc.


As part of our broader risk management processes when investing, Iron Wolf Capital has
implemented procedures to identify, measure, manage, and monitor sustainability risks.


Risk identification

Iron Wolf Capital has separately reviewed the sustainability risks that are potentially likely to cause a material negative impact on the value of its products' investments. For this, we run an analysis of potential sustainability risks relevant to our business activities. We leverage the UN PRI framework to underscore our assessment of sustainability risks.


Sustainability risks may have a significant impact on traditional investment risks and be a factor that contributes to their materiality.

Iron Wolf Capital treats sustainability risk as a standalone risk.

Sources of sustainability risk include, but are not limited to:
- Reputational risk to the investment
- Regulatory risk to the investment
- Litigation risk to the investment


Risk measurement

Sustainability risks' impact on investment returns should be assessed based on an internal
assessment of the material risks that may impact the return.

At this end, Iron Wolf Capital uses ESG questionnaires applied to all potential investments to
assess the sustainable risks linked to its investments.


Risk management & monitoring

Iron Wolf Capital takes adherence to international standards (e.g. requiring investee entities to adhere to the UN Global Compact Principles) to reduce/mitigate sustainability risks at the portfolio level.

Systematic sustainability risk monitoring is essential for proper risk mitigation in day-to-day
business operations and throughout the various investment stages. This process refers to the
action implementation such as ensuring fund managers and analysts have access to relevant information, making it possible to identify sustainability risks within the investable universe.

5. Sustainability Risks Related Remuneration Policy

Iron Wolf Capital has defined principles relating to remuneration for all employees, taking into
account the Company's structure, strategy, objectives, and risk policy, to remunerate and reward employees in a fair and motivating framework.

6. Responsibilities

The director of UAB „Iron Wolf Capital Management“ is assigned the responsibility for
the implementation of this policy and any ensuring application of related procedures.
The executive management assists with approving and conducting oversight of this policy along with its related procedures.

7. Communication

This policy is communicated on an annual basis to all employees via the normal Company
channels, including the Company’s internal rules and intranet, and is introduced to all new staff at induction.

8. Policy Revision

This policy is reviewed annually or in the event of any change in related government policy.

9. Contact

For more information, please send an email to

This policy was last approved on 22 April 2024 by the board of directors of UAB „Iron Wolf Capital Management“.

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