Statement on principal adverse impacts of investment decisions on sustainability factors

Asterion’s approach to the Sustainable Financial Disclosure Regulation

Since inception, Responsible Investment has been a key aspect of Asterion’s investment strategy. Asterion believes it is its duty to responsibly manage its third-party capital by positively contributing to the broader economy, the environment and society through the management of its portfolio companies and of Asterion as a company itself. To that end, our commitment to ESG management is central to our strategy and fully integrated in all investment processes and operations.


Regulation (EU) 2019/2088 of 27 November on sustainability-related disclosures in the financial services sector (Sustainable Financial Disclosure Regulation, SFDR), as supplemented by the Delegated Regulation (EU) 2022/1288, became applicable in March 2021. The SFDR introduces new transparency requirements among financial market participants and financial products. The objective is to allow investors to make well-informed decisions about the potential sustainability impacts of their investments, improving transparency and preventing the so-called “greenwashing”. The regulation mandates transparency by the investment manager regarding progress in achieving sustainability objectives and monitoring & managing principal adverse impacts of investments.


Below, Asterion has disclosed information required by the regulation and provides indications as to where to find additional information on Asterion’s approach to ESG and Responsible Investment.

I. Asterion Industrial Partners SGEIC SA (Asterion) is subject to the Regulation (EU) 2019/2088 of 27 November on sustainability related disclosures in the financial services sector (Sustainable Financial Disclosure Regulation, SFDR), completed by the Delegated Regulation (UE) 2022/1288.
II. Asterion Industrial Partners SGEIC SA and the Funds managed by it, integrate sustainability factors and risks into their investment decisions. Additional detail on how this process is carried out can be found in the company’s Responsible Investment Policy available on this website.
III. SFDR requires managers who consider sustainability factors to position their funds under one of three categories, according to their commitment/management of ESG. In line with this, Asterion Industrial Infra Fund II FCR (Asterion Fund II) has been classified as an “Article 8 Fund” as detailed in the Fund Prospectus and Management Regulations, both registered with CNMV.
IV. Asterion Industrial Partners SGEIC SA considers principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated principal adverse sustainability impacts statement of Asterion Industrial Partners SGEIC SA. This principal adverse impact statement covers the reference period from 1st of January 2022 onwards (any changes related to Asterion’s approach to principal adverse impact will be updated and communicated accordingly).
V. In relation to the above statement, the Management Company is committed to considering principal adverse impacts on sustainability factors in its risk assessment process, for which they will be included in the due diligence policies and processes. The progress made by Asterion in relation the principal adverse impacts will be included as part of Asterion’s ESG Annual Report, which will be published in this website on a yearly basis.
VI. Asterion’s Remuneration Policy is consistent with the company’s strategy and policies to consider and integrate sustainability risks, factors and their principal adverse impacts in its operations and investment decisions, in line with Regulation (EU) 2019/2088, of 27 November. Since 2021, Asterion remuneration policy includes a variable component of 15% of the bonus linked to the achievement of ESG targets. A defined proportion of compensation is directly linked to (1) the individual’s contribution to the firm’s ESG objectives’ attainment and strategy, and (2) specific goals for each portfolio company.


Please click here to download our Responsible Investment Policy

Please click here to download our ESG reports

Asterion environment
Climate change and low-carbon economy 
Efficient use of resources
Environmental impact on ecosystems
Asterion social
Social progress and human rights
Diversity and inclusion
Well-being in the workplace
Asterion transparency
Transparency, ethics and integrity
Shared success
Full ESG integration