Sustainable Finance Disclosure Regulation
The Sustainable Finance Disclosure Regulation1 seeks to establish a pan-European framework to facilitate Sustainable Investment.
The following disclosures relate to Guggenheim Partners Fund Management (Europe) Limited (as manager of Guggenheim Global Investment Plc and Guggenheim Partners Investment Funds Plc) and Guggenheim Partners Europe Limited (in its capacity as investment advisor and manager of European Collateralized Loan Obligations).
Integration of Sustainability Risks
Guggenheim Partners Fund Management (Europe) Limited and Guggenheim Partners Europe Limited have regard to the terms of the ESG integration statement for financial products under their respective management. In doing so ESG factors (including the consideration of sustainability risks) shall be integrated into the investment decision-making process.
Assessment of the Impact on Likely Returns
An assessment is undertaken by Guggenheim Partners Fund Management (Europe) Limited and Guggenheim Partners Europe Limited of the likely impacts of the sustainability risks, on their financial product's returns. Even where sustainability risks are identified there can be no guarantee of the correct assessment of the impact of sustainability risks on the financial product's investments or proposed investments. Where a sustainability risk occurs in respect of an asset, there could be a negative impact on, or loss of its value.
Consideration of Principal Adverse Impacts
Guggenheim Partners Fund Management (Europe) Limited and Guggenheim Partners Europe Limited do not currently consider the adverse impacts of investment decisions on sustainability factors in accordance with the Taxonomy Regulation2. The rationale for not considering such adverse impacts is on the basis that the regulatory technical standards which will set out the content, methodology and information required in the principle adverse impact statement remain in draft form and the level two regulatory technical standards (the ''RTS''), which supplements the Sustainable Finance Disclosure Regulation, has not yet come into effect. Guggenheim Partners Fund Management (Europe) Limited and Guggenheim Partners Europe Limited intend to consider the principal adverse impacts of investment decisions on sustainability factors once the RTS come into effect.
Guggenheim Partners Fund Management (Europe) Limited and Guggenheim Partners Europe Limited's remuneration policies (i) promote sound and effective risk management and (ii) discourage excessive risk taking, including without limitation, with respect to sustainability risks. A sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.
The assessment of Guggenheim Partners Fund Management (Europe) Limited and Guggenheim Partners Europe Limited's staff performance is based on a multi-year framework in order to take into account the long-term performance of staff, as well as the performance of the financial product under management. Performance objectives are therefore a multi-year process, ensuring that staff and end investors' interests are aligned.
Variable remuneration is dependent upon the performance of the business unit(s), the performance of the relevant firm and the performance of the employee concerned. This serves to discourage excessive risk taking, as no one individual can influence Guggenheim Partners Fund Management (Europe) Limited or Guggenheim Partners Europe Limited 's performance. The determination of an individual's entitlement to variable remuneration will take into account the individual staff member's performance in the relevant performance period taking into consideration both financial and non-financial criteria. As part of the measurement of performance used to calculate variable remuneration this will include the consideration of relevant types of current and future risks, including sustainability risks.
1Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector.
2Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector.
Guggenheim Investments represents the investment management businesses of Guggenheim Partners, LLC ("Guggenheim"). Guggenheim Funds Distributors, LLC is an affiliate of Guggenheim.
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*Assets under management is as of 12.31.2020 and includes leverage of $13.7bn. Guggenheim Investments represents the following affiliated investment management businesses of Guggenheim Partners, LLC: Guggenheim Partners Investment Management, LLC, Security Investors, LLC, Guggenheim Funds Distributors, LLC, Guggenheim Funds Investment Advisors, LLC, Guggenheim Corporate Funding, LLC, Guggenheim Partners Europe Limited, GS GAMMA Advisors, LLC, and Guggenheim Partners India Management. Securities offered through Guggenheim Funds Distributors, LLC.
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