SUSTAINABILITY-RELATED DISCLOSURES
This section of the website sets out the entity-level disclosures by Fengate Capital Management Ltd (“Fengate“) under Articles 3, 4 and 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 (“SFDR“).
These disclosures apply to funds (i) in relation to which Fengate acts as third-country alternative investment fund manager and (ii) that fall within the scope of the SFDR as a result of Fengate marketing the funds in the European Union.
Sustainability risk policies
In accordance with SFDR, ‘sustainability risk’ means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.
Fengate undertakes a rigorous SFDR compliance review, including in respect of sustainability risks, during the investment process which comprises: (i) sourcing, (ii) diligence, (iii) approval, and (iv) asset management. In order to integrate sustainability risks into investment decision making, Fengate performs an initial ESG screening assessment prior to making any investment decisions. Accordingly, sustainability risks are identified during the investment screening process at the diligence phase and taken into consideration prior to proceeding with an investment, with a view to ensuring that any areas of improvement are identified and implemented post-acquisition.
These risks and the approach to their assessment are presented to the Investment Committee for its consideration and approval prior to proceeding with the investment opportunity. Additionally, Fengate carries out negative screening against exclusion lists and avoids investments in projects that violate human rights, run afoul of local law, damage the environment or have unfair labour practices. Accordingly, Fengate’s investment process has been designed to ensure that sustainability risks are identified and assessed so that they are considered as part of all investment decisions taken on behalf of Fengate’s funds.
Fengate reports annually on its ESG activities as part of the Principles for Responsible Investment (“UNPRI” or “PRI”) assessment. This information can be found in the public transparency report on the PRI website.
No consideration of adverse impacts of investment decisions on sustainability factors
Fengate does not consider the adverse impact of its investment decisions on sustainability factors at an entity level in the manner prescribed by Article 4 of the SFDR. At this time, Fengate deems that its existing ESG policies and procedures are appropriate and proportionate, in view of its wider operations, for the purposes of considering ESG-related risks and opportunities.
Fengate will review its approach to considering adverse impacts of investment decisions on sustainability factors on an annual basis.
Renumeration policies
Fengate’s employees are organized and incentivized to ensure that each fund investment promotes Fengate’s desired ESG characteristics and, where applicable, is consistent with the integration of stainability risks. If a fund fails to meet its ESG goals, then a portion of the employees’ overall carried interest entitlement in that fund, regardless of its financial performance, is sacrificed. Fengate believes that ESG compliance must be embedded in remuneration, as well as the fund’s actions.
Product level information
In addition, the following in-scope funds make specific product level disclosures in accordance with Article 10 of SFDR: Fengate Infrastructure Fund IV (International) LP; Fengate Infrastructure Fund IV (International) USQ LP; Fengate Infrastructure Fund V (International) LP; and Fengate Infrastructure Fund V (USQ) LP. These product disclosures can be found in the downloadable PDFs below.
DATE: 7 November 2025
