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SFDR sustainability
risk policies


The Sustainable Finance Disclosure Regulation (“SFDR”) came into force in the EU on 10th March 2021. Marble Bar is a UK alternative investment fund manager who, with its partner firms, offers a diversified selection of alternative equity strategies. The relevant considerations for sustainability/ESG vary across these different strategies and the investment approaches of the different portfolio managers.

With the exception of Elephant Asset Management (London) LLP and Velox Capital Partners LLP, Marble Bar and its partner firms do not take into account the EU criteria for environmentally sustainable economic activities, nor do they integrate sustainability risks into their investment decision making processes. Further information in relation to the ESG integrated investment approach taken by Elephant Asset Management (London) LLP and Velox Capital Partners LLP is set out below.

Elephant Asset Management (London) LLP SFDR Sustainability Risk Policy

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Velox Capital Partners LLP SFDR Sustainability Risk Policy

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no consideration of
sustainability adverse impacts

Marble Bar does not consider the principal adverse impacts of investment decisions on sustainability factors, nor does it currently plan to do so. Marble Bar operates a number of investment portfolios for clients with varying investment strategies and objectives.

Marble Bar does not consider it appropriate to apply a standardised approach to considering sustainability adverse impacts across all portfolios. Such assessment must therefore be conducted at portfolio level. Relevant information is made available in product level pre-contractual disclosures.


remuneration policy

Marble Bar has in place a Remuneration Policy in accordance with the provisions of the FCA Handbook. Staff members are paid various forms of remuneration on a fixed basis. In addition, certain staff members may be paid a variable discretionary annual bonus. The total amount of variable remuneration is based on a combination of the assessment of the staff member’s

performance and the overall results of the firm and the product (where relevant), as well as the staff member’s conduct in accordance with the firm’s policies, procedures and compliance requirements. This includes, where relevant, the integration of sustainability risks in the investment decision-making process.



Velox Capital Partners LLP Website Product Disclosures

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Elephant Asset Management (London) LLP Website Product Disclosures

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