Integration of Sustainability Risks

Sustainability Risks mean an environmental, social, or governance event or condition that, if it occurs, could potentially or actually cause a material negative impact on the value of a sub-fund’s investment. Sustainability risks can either represent a risk of their own or have an impact on other risks and may contribute significantly to risks, such as market risks, operational risks, liquidity risks or counterparty risks. Sustainability risks may have an impact on long-term risk adjusted returns for investors. Assessment of sustainability risks is complex and may be based on environmental, social, or governance data which is difficult to obtain and incomplete, estimated, out of date or otherwise materially inaccurate. Even when identified, there can be no guarantee that this data will be correctly assessed.

Approach to sustainable finance and sustainability does not have common standards and can be subjective and may evolve and develop over time also due to legal and regulatory requirements. Therefore, comparability between various sustainable products may be difficult.

Lack of common or harmonised definitions and labels integrating ESG and sustainability criteria prevail at EU level. Inadequacy of such information may result in different approaches by managers when setting ESG objectives and determining that these objectives have been met by the managed funds. Furthermore, this implies it may be difficult to compare strategies integrating ESG and sustainability criteria to the extent that the selection and weightings applied to select investments may be subjective or based on metrics that have the same name but different underlying meanings. Therefore, Gyra Funds Lux chose to be a non-ESG fund.

Gyra recognises that sustainability is an ongoing and evolving topic.


Gyra does not invest in sovereign bonds issued by countries that are subject to an arms embargo by the UN Security Council. Furthermore, Gyra does not invest in companies involved in the manufacture of landmines, chemical or biological weapons, or nuclear weapons made in violation of the Nuclear Non-Proliferation Treaty.

Principle Adverse Impact

For the time being, except as may be otherwise disclosed at a later stage on this website, Gyra does not consider adverse impacts of investment decisions on sustainability factors. The main reason is lack of information and data available to adequately assess such principal adverse impacts.

Sustainability Risk Effect on Remuneration Policy

Gyra SA's current remuneration policy does not fully consider sustainability risks, with the exception of certain measures. The company offers fixed forms of remuneration, including annual discretionary bonuses that are determined based on an employee's performance. The total amount of variable remuneration is determined by assessing the individual's performance, as well as the performance of the relevant product and adherence to internal procedures, policies, and compliance requirements, which may include considerations of sustainability risks. This policy is subject to regular review and revisions. Gyra aims to create a fair, transparent, motivating and aligned salary model for its employees.

[1] In accordance with SFDR, Sustainable Finance Disclosure Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 with regards to sustainability-related disclosures in the financial services sector.