SFDR Statement


Saratoga Capital Partners Ltd. makes the following “Statement” in relation to the Transparency of Sustainability Risk Policies and Adverse Sustainability Impacts pursuant to 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”).

Environmental, social, and corporate governance or “ESG” is a set of considerations, including environmental issues, social issues and corporate governance that can be considered in investing. Investing with ESG considerations is sometimes referred to as responsible investing or, in more proactive cases, impact investing.

This Statement in relation to SFDR and ESG may be updated from time-to-time. We therefore ask you to consult it on a regular basis. The last line below indicates when the Statement was last updated.

Integration of sustainability risks

Although Saratoga Capital Partners Ltd. is not obligated to provide a sustainability risks statement, we have decided to publish on our website information about our policies on the integration of sustainability risks in our investment decisions-making process.

As of the date of this Statement, Saratoga Capital Partners Ltd. does not consider specific ESG principles at the entity level nor does any of our investments under management have sustainable investment as part of their respective investment objectives, strategies or policies for the purposes of Article 9 of the SFDR.

Notwithstanding the foregoing, Saratoga Capital Partners Ltd. does consider ESG matters to be of high importance and intends to gradually integrate considerations and their implications within the investment assessment, decision-making process and risk exposure of each investment under management, unless otherwise stated in the relevant fund documentation.

Accordingly, Saratoga Capital Partners Ltd. will gradually implement processes on reviewing and re-assessing the risk profiles of its investments so as to integrate the potential impact of sustainability risks directly or indirectly through other, already-identified investment risks such as market risks, operational risks, liquidity risks, credit risk/counterparty risks, funding risks or reputational risks.

Transparency of adverse sustainability impacts

Saratoga Capital Partners Ltd. acknowledges that certain of its investments may be negatively impacted by sustainability risks and that sustainability risks may impair the value of the investments made. However, Saratoga Capital Partners Ltd. does not currently consider the adverse impacts of its investment decisions on sustainability factors. Saratoga Capital Partners Ltd. might reconsider its position in the future so as to take into account the adverse impacts on its investment decisions on sustainability factors.

Transparency of remuneration policy in relation to the integration of sustainability risks

It is the policy of Saratoga Capital Partners Ltd. to maintain remuneration arrangements that, among other things, do not encourage risk-taking (including in respect of exposure to sustainability risks as defined in the SFDR) that is inconsistent with the relevant risk profile of our respective investment.

Transparency in pre-contractual disclosures

All assets as managed by Saratoga Capital Partners Ltd. may include relevant descriptions in pre‐contractual disclosures – i.e., private offering memoranda, prospectuses, etc. – on how sustainability risks are integrated into investment decisions, as well as the results of the assessment of the likely impacts of sustainability risks on the financial returns of investments under management.

Where sustainability risks are not deemed relevant, a clear and concise explanation of the reasons for such a decision may be included. Further, where appropriate, all documentation disclosed by Saratoga Capital Partners Ltd. may include in their disclosures a statement on how Principal Adverse Impacts (“PAI”) are considered or a statement that PAIs are not considered and the reasons therefor.


This policy was last updated on 01.01.2024.