PRIVACY POLICY
This privacy policy (“Privacy Policy”) explains how Titanbay Ireland Limited (“Titanbay”, “we”, “us” or “our”), collects, uses, shares and otherwise processes your Personal Data (defined below) in connection with your relationship with us in accordance with applicable data privacy laws, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (“GDPR”). Unless you are otherwise advised via any other documentation or notification received from us or our affiliates, we shall be the Data Controller in respect of the personal data described in this Privacy Policy, meaning we determine the means and purposes of processing the Personal Data.
The information set out herein applies to the personal information (also known as “Personal Data”) that we collect about you when you visit our website and/or access our online portal.
What is Personal Data?
The term “Personal Data” as used in this Privacy Policy means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, by reference to an identifier. This definition provides for a wide range of personal identifiers which may constitute Personal Data, including name, date of birth, residential address, identification number, location data or online identifier. Personal Data does not include data from which you can no longer be identified such as anonymised aggregate data.
What are cookies and how do we use them?
Cookies are small text files that can be used by websites to make a user's experience more efficient. This website and our platform use cookies which are unique to your web browser. They will contain some anonymous information such as a unique identifier and some digits and numbers.
Performance cookies will only be used on our website ( www.titanbay.com ) if you consent to them through our cookie banner.
A condition of use of our platform is that cookies will be placed to record usage, to analyse the user experience and enable optimisation of the service.
How to change or delete cookies?
If you want to restrict or block the cookies set by our website, you can do so through the cookie banner or through your browser settings. Alternatively, you can visit www.internetcookies.com which contains comprehensive information on how to do this on a wide variety of browsers and devices. You will find general information about cookies and details on how to delete cookies from your device.
How do we collect personal data and what kind of information do we collect?
A detailed description of why and on what legal basis we process Personal Data, and the types of Personal Data we process for each purpose, is set out below (see “Detailed Description of Processing”).
General browsing will utilise cookies as outlined above. In the event you open an account with us, fill out a “contact us” form on our website or subscribe to our newsletter, the kinds of Personal Data we may collect include information such as:
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your contact details (such as your address, email address and telephone number) and other information such as your job title. In most cases, we will collect the Personal Data directly from you but may also obtain it from other sources;
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personal details, such as (e.g. name, gender, date and place of birth, occupation, address, email address, phone numbers, identity documents, financial information and other contact details information);
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other materials we may need for our identification and compliance obligations as well as information from third party providers who assist us to combat fraud, money laundering and other crimes;
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complaints or disputes you may have had with us or other members of the group and details of the underlying transaction (where applicable);
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sales and marketing information;
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financial information and transactions records;
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records of correspondence and other communications between you and your representatives;
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information that we need to support our regulatory obligations; and
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any other information you asked and authorised us to collect for or about you.
What do we do with your data?
We may use automated decision making in processing your Personal Data, subject to the GDPR requirements in relation to the same. We may assess certain characteristics on the basis of Personal Data processed automatically (profiling), in particular to provide you with information on our products and services or those of our affiliates and business partners. We may also use technologies that allow identifying the level of risks linked to the activity within your investment portfolio. You can request a manual review of the accuracy of the automated decision.
We may aggregate and/or de-identify any information collected so that such information can no longer be linked to you or your device or is otherwise no longer Personal Data per the meaning of the GDPR. We may use such information for any purpose subject to applicable law, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, partners, and sponsors.
We will process your Personal Data if and to the extent applicable law provides us with a lawful basis to do so.
Therefore, we will only process your Personal Data on the following grounds:
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Consent - you have consented to us using your data;
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Contract - we need it to perform the contract we have entered into with you;
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Legal Obligation - we need it to comply with a legal obligation; or
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Legitimate Interest - we (or a third party with whom we work with) have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Legitimate interest may include the provision of services by us, administrative or operational processes within Titanbay and certain direct marketing activities. We will use your Personal Data to deliver services to you and/or to work or act for you. We may also use your Personal Data to inform you about us and our services or otherwise communicate with you.
Please note that we may use or disclose Personal Data if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
Detailed Description of Processing
Purpose of Processing
To communicate with, pay funds to, keep records for, contract with, and provide services to investors (including prospective investors, herein referred collectively as “Investor” or “Investors”), vendors, partners, or other contacts;
To perform marketing and research services for Investors;
To perform background screening of Investors, investment partners, and prospective/current/retired/ex- employees;
To perform employment decisions and screenings of prospective employees;
To perform employee recruiting;
To authenticate users; and
To meet relevant regulatory requirements.
Categories of Personal Data Processed
Contact Information including name, telephone number, address, email address, and signature
Legitimate interest
Legal Basis for Processing
Performance of contract
Legal compliance
Consent (where applicable)Employment (where applicable)
Purpose of Processing
To perform background screening of Investors, investment partners, and prospective/current/retired/ex- employees.
Categories of Personal Data Processed
Employment Information including title/role, institution/company, location, compensation, work history, and qualification/training
Legal Basis for Processing
Legitimate interest
Legal compliance
Performance of contract
Consent (where applicable)
Purpose of Processing
To perform fund/subscription processes, accounts, records, marketing, and onboarding services for Investors;
To perform background screening of Investors, investment partners, and prospective/current/retired/ex- employees;
To meet relevant regulatory requirements; and
To communicate with, pay funds to, keep records for, contract with, and provide services to Investors, vendors, and employees.
Categories of Personal Data Processed
Account/Financial Information including Contact Information, date of birth, bank account information, wire transfer information, expense details, beneficiary designation, Investor commitments, ledgers, positions, balances, percentages of fund, credit information, investment history, net worth, source of wealth, employment history, personal financial portfolio, education history and share or option numbers, values, and vesting
Legal Basis for Processing
Legitimate interest
Performance of contract
Legal compliance
Employment (where applicable)
Purpose of Processing
To perform marketing and research services for Investors;
To perform background screening of Investors, investment partners, and prospective/current/retired/ex- employees;
To meet relevant regulatory and legal requirements;
To comply with tax requirements; and
To accept/process funds from, pay funds to, keep records for, contract with, and provide services to Investors, partners and employees.
Categories of Personal Data Processed
Government Identification Information including taxpayer identification number, date of birth, driver’s license, passport, other official government identification and numbers, legal work status, and Know Your Client (“KYC”) details
Legal Basis for Processing
Legitimate interest
Performance of contract
Legal compliance
Consent (where applicable)
Employment (where applicable)
Purpose of Processing
To meet relevant regulatory requirements; and
To perform background screening of Investors, investment partners, and prospective/current/retired/ex- employees.
Categories of Personal Data Processed
Certification Information including business partners or employee certification / accreditation details, conflicts information, approvals, registrations, licenses, and consents
Legal Basis for Processing
Legitimate interest
Legal compliance
Consent (where applicable)
Employment (where applicable)
Purpose of Processing
To secure physical and digital access control, electronic communications, and electronic asset management;
To perform marketing and research services for Investors; and
To perform investment presentations.
Categories of Personal Data Processed
Identification Information including photo, log-ins, dial-ins, and codes
Legal Basis for Processing
Legitimate interest
Employment
Information Collected Automatically
As is true of most digital platforms, we may gather certain information automatically when you use our services online.
This information may include browser, device, cookie and similar data that we collect as follows:
Purposes of Processing
To maintain the security of Titanbay services, for fraud detection, and to protect Titanbay’s rights; and
To manage Titanbay services and email messages and to collect and track information about user activities online over time and across different websites and social media channels.
Categories of Personal Data Processed
Internet or other electronic network activity including IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data
Legal Basis for Processing
Legitimate Interests
Purposes of Processing
To manage Titanbay services and email messages and to collect and track information about user activities online over time and across different websites and social media channels to personalise content.
Categories of Personal Data Processed
Cookies, Analytics and Related Technologies
Legal Basis for Processing
Legitimate Interests
Consent (where applicable)
Purposes of Processing
To offer certain location-based services, such as delivering marketing that is location-relevant, and to conduct analytics to improve Titanbay services.
Categories of Personal Data Processed
Location Information including latitude, longitude, date, and time (the precision of this data varies greatly and is determined by factors controlled by your device or mobile service provider)
Legal Basis for Processing
Legitimate Interests
Consent (where applicable)
Purposes of Processing
To authenticate users;
To secure digital access control for employees; and
To perform recordkeeping and tracking in enterprise and storage software for employees.
Categories of Personal Data Processed
Access Control Information including user names, email address, IP address, and location pings
Legal Basis for Processing
Legitimate Interests
What might we need from you?
We may need to request specific information from you to help us confirm your identity and ensure your right of access to your Personal Data (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
Accuracy of information
It is important that the Personal Data we hold about you is accurate and current. Please let us know promptly if your Personal Data changes during your relationship with us.
What if you do not provide the Personal Data we request?
It is in your sole discretion to provide Personal Data to us. If you do not provide us with all or some of the Personal Data we request, we may not be able to send you information about us (e.g. marketing materials), accept an engagement from you to provide all or some of our services or, to enter into a contract with you.
Change of purpose and anonymisation
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
With whom will we share your information?
When using your Personal Data for the purposes and on the legal basis described above we may share your Personal Data with other service providers we work with. This includes but may not be limited to, other entities within the Titanbay group of companies. We may also have to share your Personal Data with regulators, public institutions, courts or other third parties.
Category of Recipients
Customers, Suppliers, Service Providers, Vendors, Other Commercial Entities
Personal Data Shared
Contact Information including name, telephone number, address, email address, and signature
Account/Financial Information including Contact Information, date of birth, bank account information, wire transfer information, expense details, beneficiary designation, Investor commitments, ledgers, positions, balances, percentages of fund, credit information, investment history, net worth, source of wealth, employment history, personal financial portfolio, education history and share or option numbers, values, and vesting
Government Identification Information including taxpayer identification number, date of birth, driver’s license, passport, other official government identification and numbers, legal work status, and Know Your Client (“KYC”) details
Identification Information including photo, log-ins, dial-ins, and codes
Purposes for which the Personal Data is Shared
To enable us to carry out the obligations under and enforce our contracts with our customers, suppliers, service providers, vendors and other commercial entities.
Category of Recipients
Service Providers, Agents
Personal Data Shared
Contact Information including name, telephone number, address, email address, and signature
Account/Financial Information including Contact Information, date of birth, bank account information, wire transfer information, expense details, beneficiary designation, Investor commitments, ledgers, positions, balances, percentages of fund, credit information, investment history, net worth, source of wealth, employment history, personal financial portfolio, education history and share or option numbers, values, and vesting
Government Identification Information including taxpayer identification number, date of birth, driver’s license, passport, other official government identification and numbers, legal work status, and Know Your Client (“KYC”) details
Identification Information including photo, log-ins, dial-ins, and codes
Certification Information including business partners or employee certification / accreditation details, conflicts information, approvals, registrations, licenses, and consents
Purposes for which the Personal Data is Shared
To anyone providing a service to us or acting as our agent, as data processors, or for the purposes of providing services to us and on the understanding that they will keep the personal data confidential and only process it in accordance with our instructions and the GDPR.
Category of Recipients
Auditors, Legal Advisors, Other Advisors
Personal Data Shared
Contact Information including name, telephone number, address, email address, and signature
Account/Financial Information including Contact Information, date of birth, bank account information, wire transfer information, expense details, beneficiary designation, Investor commitments, ledgers, positions, balances, percentages of fund, credit information, investment history, net worth, source of wealth, employment history, personal financial portfolio, education history and share or option numbers, values, and vesting
Certification Information including business partners or employee certification / accreditation details, conflicts information, approvals, registrations, licenses, and consents
Purposes for which the Personal Data is Shared
Where we need to share personal data with our auditors, legal and other advisors.
Category of Recipients
Regulatory bodies
Personal Data Shared
Employment Information including title/role, institution/company, location, compensation, work history, and qualification/training
Certification Information including business partners or employee certification / accreditation details, conflicts information, approvals, registrations, licenses, and consents
Government Identification Information including taxpayer identification number, date of birth, driver’s license, passport, other official government identification and numbers, legal work status, and Know Your Client (“KYC”) details
Purposes for which the Personal Data is Shared
Where we are required or requested to share information with a regulatory or oversight body.
For the purposes described above, from time-to-time, we may have to transfer your Personal Data from the European Economic Area (EEA) to a third party outside of the EEA and in a jurisdiction not being subject to an adequacy decision of the European Commission. Details of any such jurisdictions are set out in the Appendix hereto, which may be updated from time to time. In such cases, we will always ensure that there is a legal basis and a relevant safeguard method for such data transfer so that your Personal Data is treated in a manner that is consistent with and respects the EU laws and other applicable laws and regulations on data protection.
Disclosure of Personal Information to Affiliates
Titanbay may share Personal Data with its affiliates to the extent necessary or appropriate for such affiliates to perform services for your benefit, provided that such affiliates will be obligated to keep such personal information confidential to the same extent as Titanbay.
Third Parties
The website may, from time to time, include links to third-party websites or enable individuals the opportunity to disclose information directly to third parties. This Privacy Policy does not apply to such third-party websites or organisations. You assume all privacy, security, and other risks associated with providing any data, including personal information, to third parties via the website. For a description of the privacy protections associated with providing information to third parties, you should refer to the privacy statements, if any, provided by those third parties.
Third Parties: Analytics
This website and the Titanbay platform use Cookiebot, Google Analytics and Heap Analytics to understand how our website and platform are used, so we can improve performance. These tools may use first- and third-party cookies to collect usage data like page views and device information. Cookiebot helps manage your consent in line with GDPR. Data is used for analytics only, and we do not sell or profile your data. Information is processed securely by our providers and not shared further.
Your rights in relation to your information
You have rights as an individual which you can exercise under certain circumstances in relation to your Personal Data that we hold. These rights are to:
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request access to your Personal Data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
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request rectification of your Personal Data;
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request the erasure of your Personal Data;
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request the restriction of processing of your Personal Data;
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object to the processing of your Personal Data where we are relying on our legitimate interest(s) (or those of a third party) as a lawful basis for such processing;
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request the transfer your Personal Data to another organisation, or directly to you, under certain conditions; and
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not be subject to solely automated decision making, including profiling, which produces a legal effect or other similarly significant effect on you. This right is subject to certain restrictions and safeguards, and does not apply where the decision is (a) necessary for entering into or performance of a contract with you or (b) authorised by EU or member state law or (c) based on your explicit consent.
You also have the right to make a complaint at any time to the Data Protection Commission using the contact form at https://forms.dataprotection.ie/contact. You also have the right to make a complaint via your local national data protection regulator.
If you wish to receive a copy of personally identifiable data we store about you, this can be made available on request. Once we have verified your identity, we will supply you with a digital record of all your personal data as soon as we can, but in any event, it will be within one calendar month.
We will not charge you for supplying copies of your personal data in the first instance. However, in the event we find data subject access requests to be manifestly unfounded or excessive, particularly where repetitive, we will need to consider the effort required to handle such requests and charge a reasonable administrative fee.
Right to withdraw consent
In case you have provided your consent to the collection, processing and transfer of your Personal Data, you have the right to fully or partly withdraw your consent (which will not affect the lawfulness of any processing done before the consent was withdrawn). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. In case we processed your Personal Data for direct marketing purposes, you have the right to object at any time, in which case we will no longer process your Personal Data for such marketing purposes.
How long will we retain your information?
We will only retain your Personal Data for as long as is necessary to fulfil the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements, or to enforce our terms and conditions or for the protection of our rights in the context of legal claims, litigation, arbitration or similar proceedings.
To determine the appropriate retention period for your Personal Data, we will consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case it is no longer Personal Data.
Upon expiry of the applicable retention period we will securely destroy your Personal Data in accordance with applicable laws and regulations.
Changes to this Privacy Policy
Titanbay reserves the right to update this Privacy Policy at any time, and we will make an updated copy available on our website.
Further information
In our capacity as data controllers for this website, if you have any queries, questions, concerns or require any further information in relation to the Privacy Policy or you wish to exercise any of your rights, please do not hesitate to contact us at compliance@titanbay.ie.
We endeavour to respond to all legitimate requests within one calendar month. Occasionally it may take us longer than one calendar month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated and endeavour to respond to your request as soon as reasonably practicable.
Date: September 2025
APPENDIX
Jurisdictions outside of the EEA not being subject to an adequacy decision of the
European Commission to which your data may be transferred
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None
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This cookie policy explains how Titanbay Ireland Limited (together, “Titanbay”, “we”, “us” or “our”),
utilises cookies in accordance with applicable data privacy laws, including Regulation (EU) 2016/679 of
the European Parliament and of the Council of 27 April 2016, known as the General Data Protection
Regulation (“GDPR”) and the ePrivacy Directive (Directive 2002/58/EC, as implemented in national law).
Where applicable, this policy also extends to any affiliates of Titanbay that operate services accessible via
this website.
What Are Cookies?
Cookies are small text files that can be used by websites to make a user's experience more efficient. This
website and our platform use cookies which are unique to your web browser. They will contain some
anonymous information such as a unique identifier and some digits and numbers.
Why We Use Cookies
We use cookies to personalise content and ads, to provide social media features and to analyse our
traffic. We also share information about your use of our website with our social media, advertising and
analytics partners who may combine it with other information that you’ve provided to them or that they’ve
collected from your use of their services.
Our legal basis for using cookies depends on the type of cookie. Essential cookies are used on the basis
of our legitimate interest in providing a functional website. For all other types of cookies, we rely on your
consent.
Types of Cookies We Use
This website uses different types of cookies. Some cookies are placed by third party services that appear
on our pages.These small data files or graphic files serve various functions:
- Essential cookies: These are required for the basic functions of the website.
- Functional cookies: These enable a website to remember information that changes the
way the website looks or behaves (e.g., language preferences).
- Analytical cookies: These enable a website to analyse usage in order to measure and
improve performance (e.g., Cookiebot, Google Analytics and Heap Analytics).
- Marketing cookies: These enable tracking technologies to collect data about user
behaviour on the website or across websites.
Your Consent and Choices
The law states that we can store cookies on your device if they are strictly necessary for the operation of
this website. For all other types of cookies we need your permission.
You can manage or withdraw your consent to non-essential cookies (i.e. functional cookies,
analytical cookies and marketing cookies) at any time by adjusting your preferences through
the cookie banner on our website.
If you want to restrict or block the cookies set by our website, you can do so through the cookie banner
or through your browser settings. For more information, you can visit:
www.allaboutcookies.org
www.youronlinechoices.eu
These resources provide comprehensive guidance on managing cookies across a wide variety of
browsers and devicesWe strive to provide the highest possible standard of service to our clients. However, we acknowledge there may be instances where you feel we have fallen short of this. If this happens, we encourage you to raise a complaint.
This Complaints Procedure outlines who can raise a complaint, the process for raising a complaint, the procedure in place to answer your complaint, and the next steps you may take if you remain unsatisfied with our answer.
Who can complain
If we have provided a service to you then you may raise a complaint with us.
Raising a complaint
To ensure your complaint reaches the correct team internally, we encourage you to raise your complaint by emailing Titanbay’s Designated Person with responsibility for Regulatory Compliance, (the "Designated Person") and include ‘Complaint’ in your email’s subject line. The contact information for the Designated Person is:
Email: compliance@titanbay.ie
Answering your complaint
Upon receipt of your complaint, we will acknowledge your complaint as soon as reasonably practicable and in any case within 5 business days of receipt. We will investigate your complaint to provide a fair and reasonable answer. We may request further information from you when this is required to properly assess your case.
We aim to provide you with a final written answer to your complaint within 40 business days after we received your complaint. If we are unable to answer you within this time, we will contact you to let you know and explain the reasons for this. We will also provide you with a date by which the complaint may be resolved.
If you are not satisfied
If you are not satisfied with our final response, or 40 business days have passed since you made your complaint, then you may escalate your complaint to the Financial Services and Pensions Ombudsman. Their contact details are:
Lincoln House
Lincoln Place
Dublin 2
D02 VH29
+353 1 567 7000
https://www.fspo.ie/make-a-complaint/how-to-make-a-complaint-to-the-fspo/
SFDR Entity-Level Disclosure Statement
Sustainability Risk Policy and Principal Adverse Impact Statement
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Introduction
Titanbay Ireland Limited (the “Company”) is an alternative investment fund manager (“AIFM”) authorised and regulated by the Central Bank of Ireland pursuant to the European Union (Alternative Investment Fund Managers) Regulations 2013 (as amended) (the “AIFM Regulations”), including both Regulation 7(4)(a) and Regulation 7(4)(b)(iii) of the AIFM Regulations.
The Company is authorised to manage and distribute Luxembourg-domiciled alternative investment funds, including Reserved Alternative Investment Funds (“RAIFs”) and, in the future, may manage and distribute other fund vehicles such as undertakings for collective investment governed by Part II of the Luxembourg Law of 17 December 2010 on undertakings for collective investment (“UCI Part II Funds”). The Company is also authorised for MiFID Top-Up activities, notably Receipt and Transmission of Orders and Individual Portfolio Management.
As per 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, as amended (“SFDR”), the Company is defined as a “financial market participant” in respect of both its AIFM activities and its Individual Portfolio Management activities.
This Statement sets out the Company’s entity-level disclosures required under Articles 3 and 4 of SFDR. Information on how the Company’s remuneration policies are consistent with the integration of sustainability risks, as required by Article 5 of SFDR, is set out in the Company’s Remuneration Policy, which is published separately on the Company’s website.
2. Sustainability Risk Policy
2.1. Definition
For the purpose of this Statement, “sustainability risk” means 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. Examples include widespread flooding across parts of the UK or high workforce turnover as a result of poor employment practices.
This Statement has been established pursuant to Article 3 of SFDR and Commission Delegated Regulation (EU) 2021/1255 (“CDR 2021/1255”), which requires financial market participants to publish information about their policies on the integration of sustainability risks in their investment decision-making process.
2.2 Integration of Sustainability Risks into Investment Decision-Making
The Company has established, implemented and maintains this Sustainability Risk Policy in a manner proportionate to the nature, scale and complexity of its activities and consistent with the risk profiles of the financial products it manages.
The Company integrates sustainability risks into its investment decision-making process at all relevant stages, including:
• Investment due diligence: The Company considers sustainability risks when researching potential investments. This includes reviewing a target fund investment’s ESG policies, processes and governance practices, enabling the Company to identify investment opportunities consistent with its investment policy and with strong potential for long-term financial performance.
• Investment selection: The Company selects investments in target fund investments based on a holistic assessment of both financial and sustainability factors, and assesses the potential impact of sustainability risks on expected returns.
The Company has the option to leverage external specialists and/or partners to perform enhanced ESG due diligence on prospective target funds. The Company has enhanced its existing risk management frameworks to account for the integration of sustainability risks into investment decision-making.
The Company ensures that disclosures made in pre-contractual documents are consistent with the investment objectives of the financial products it manages.
2.3. Governance
The Designated Person for Investment Management is responsible for ensuring all investments are in line with the Company’s sustainability obligations. The Chief Risk Officer is responsible for reviewing this Statement.
3. Principal Adverse Impact Statement
3.1. Entity-Level Position
In accordance with Article 4(1)(b) of SFDR, the Company does not currently consider principal adverse impacts (“PAIs”) of investment decisions on sustainability factors at entity level. The Company has fewer than 500 employees and is therefore not subject to the mandatory PAI consideration obligation under Article 4(3) of SFDR. This Statement applies solely to the Company’s entity-level assessment and reporting obligations under SFDR.
3.2. Reasons for Not Considering Principal Adverse Impacts at Entity Level
The Company has determined that it is not appropriate, at this time, to consider PAIs at entity level for the following reasons:
• The legal and technical requirements for identifying, measuring, aggregating, weighting and mitigating PAI indicators under Commission Delegated Regulation (EU) 2022/1288 are complex, prescriptive and continue to evolve.
• The availability, quality and comparability of the data required to assess PAIs, particularly in the context of private markets and private equity fund investments, remain limited.
• In many cases, the relevant data may be incomplete, estimated, based on assumptions, or otherwise not sufficiently reliable to support a robust and consistent entity-level assessment.
• Given the nature of the Company’s investment activities, including investments made through underlying funds managed by third-party managers, the Company does not currently have direct and consistent access to the data required to perform meaningful entity-level PAI calculations.
Accordingly, the Company considers that an entity-level assessment of PAIs would not, at present, provide an accurate or reliable representation of sustainability impacts.
3.3. Product-Level Consideration of Principal Adverse Impacts
The Company’s decision not to consider PAIs at entity level does not preclude certain financial products managed by the Company from considering PAIs at product level.
Where a financial product considers PAIs on sustainability factors, this is disclosed at product level in accordance with Article 7 of SFDR and the applicable regulatory technical standards, including in pre-contractual and website disclosures.
3.4. EU Taxonomy
At entity level, the Company does not take into account the EU criteria for environmentally sustainable economic activities as set out in Regulation (EU) 2020/852 (the “Taxonomy Regulation”) for the purposes of assessing PAIs.
Any information relating to Taxonomy alignment, or the lack thereof, is disclosed at product level where required.
4. Remuneration Policy (Article 5, SFDR)
Information on how the Company’s remuneration policies are consistent with the integration of sustainability risks, as required by Article 5 of SFDR, is set out in the Company’s Remuneration Policy, which is published on the Company’s website.
5. Review and Future Consideration
This Statement is subject to at least annual review and approval by the Board of Directors. The Company will continue to monitor regulatory developments, supervisory guidance, data availability and market practices.
The Company will reassess its position on the consideration of PAIs at entity level if and when it considers that the necessary data, methodologies and regulatory clarity are sufficiently developed to support a robust and proportionate assessment.
6. Further Information
For further information regarding this Statement, please contact: compliance@titanbay.ie.
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Summary
EPM Private Opportunities ELTIF (the “Feeder Fund”) is classified as an Article 8 financial product under Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”). This means the Feeder Fund promotes environmental and social characteristics. The Feeder Fund is a feeder ELTIF (as such terms is construed under the ELTIF Regulation).
The Feeder Fund pursues its investment objective by investing substantially all of its assets (target: 99%) into LBPAM Private Opportunities (the “Master Fund”), Managed by LBP AM. The Master Fund, in turn, invests in other investment funds, whether managed by its own management company or by third-party managers, which promote environmental and/or social characteristics or which have a sustainable investment objective, and whose ESG methodologies are assessed as sufficiently robust by LBP AM.
2. No sustainable investment objective
The Feeder Fund does not have a sustainable investment Objective but does promote environmental and social characteristics and is therefore classified as an Article 8 financial product under SFDR, not an Article 9 product.
Although sustainable investment is not its objective, the Feeder Fund has made a voluntary commitment to indirectly invest a minimum of 25% of its net assets in investments that qualify as sustainable investments. This commitment is binding and forms part of the Feeder Fund’s asset allocation obligations, as further described in the “Proportion of Investments” section below.
Sustainable investments are not made directly at the level of the Feeder Fund or the Master Fund. Given the Feeder Fund’s feeder fund structure, sustainable investments are made at the level of the underlying investment funds in which the Master Fund invests. Each underlying investment fund manager is responsible for determining whether its investments qualify as sustainable investments, and may apply its own definitions and methodologies for this purpose. These may differ between funds.
Details of the sustainable investment objectives and definitions applied by underlying investment funds are set out in the relevant pre-contractual disclosures of those funds.
3. Environmental or social characteristics of the financial product
The Feeder Fund promotes environmental and social characteristics indirectly by investing substantially all of its assets (target: 99%) into the Master Fund.
The Master Fund, in turn, invests in underlying investment funds which:-
Promote environmental and/or social characteristics; and/or
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Have a sustainable investment objective within the meaning of SFDR,
and whose ESG methodologies are assessed as sufficiently robust by the Master Fund management company.
No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by the Feeder Fund.
4. Investment Strategy
The Feeder Fund achieves the environmental and social characteristics it promotes through the investment strategy applied by the Master Fund.
Investments in investment funds managed by third-party management companies
For such investments, the Master Fund management company relies on ESG rating methodologies applied at management company level, which assess in particular:-
Whether the management company is a signatory to the UN Principles for Responsible Investment (UN PRI);
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The integration of ESG criteria into investment decision-making and monitoring;
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Governance practices at the level of the management company and underlying portfolio companies; and
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ESG engagement practices implemented by the management company.
Investments in investment funds managed by the Master Fund management company
Where the Master Fund invests in funds managed by its own management company, those funds apply a proprietary socially responsible investment (SRI) approach aimed at identifying issuers that:-
Provide solutions to long-term environmental and social challenges; and
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Anticipate sustainability risks through responsible conduct.
This approach is structured around four pillars:
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Responsible governance;
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Sustainable resource management;
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Energy transition; and
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Development of territories.
Binding Elements of the Investment Strategy
The following elements are binding on an ongoing basis:-
For investments in investment funds managed by third-party management companies (excluding money market funds):
The ESG rating of the management company must be at least “B”.
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Furthermore, for investments in investment funds managed by the Master Fund management company:
the application of an exclusion policy, which excludes investments relating to:
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Cluster munitions;
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Tobacco production;
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Prostitution and exploitation of prostitution;
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Gambling;
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Severe, systematic and unremedied human rights violations; and
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Coal, oil and gas activities, in accordance with the applicable exclusion policy.
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No committed minimum reduction rate is applied prior to the application of the investment strategy.
Good Governance Practices
Good governance practices are assessed as follows:-
For investment funds managed by the Master Fund management company, governance is a core component of ESG analysis and covers matters such as balance of power, executive remuneration and business ethics.
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For investment funds managed by third-party management companies, governance assessments are carried out by the respective management companies of the underlying investment funds.
The Master Fund management company ensures that the methodologies applied by underlying investment funds appropriately assess good governance practices.
5. Proportion of Investments
The Feeder Fund commits to:-
At least 65% of its portfolio being invested in investments aligned with the environmental and social characteristics promoted; and
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At least 25% of its net assets are being invested in sustainable investments.
The remaining portion of the portfolio may be used for hedging, liquidity management, diversification or return-seeking purposes, and no minimum environmental or social safeguards apply to those investments.
6. Monitoring of Environmental or Social Characteristics
The monitoring of the environmental and social characteristics promoted by the Feeder Fund operates at two levels: at the level of the Master Fund, by its management company, LBP AM; and at the level of the Feeder Fund, by Titanbay Ireland Limited (the “AIFM”).
Monitoring by LBP AM (Master Fund level)
LBP AM is responsible for monitoring compliance with the sustainability constraints applicable to the Master Fund as set out in the Master Fund’s own prospectus. This includes ongoing monitoring of the sustainability indicators described in the “Methodologies” section of this disclosure, in particular the ESG ratings of the third-party management companies whose investment funds the Master Fund invests in.
LBP AM’s monitoring is conducted by its investment and risk management functions, and compliance with the extra-financial management process is subject to periodic review by LBP AM’s Compliance and Internal Control function.
Information on LBP AM’s responsible investment practices is published in LBP AM’s annual Responsible Investment report, available on the LBP AM website.
Oversight by the AIFM (Feeder Fund level)
Titanbay Ireland Limited, as AIFM to the Feeder Fund, monitors on an ongoing basis the continued alignment of the Master Fund with the environmental and social characteristics promoted by the Feeder Fund.
This monitoring forms part of the AIFM’s broader due diligence and oversight of the Master Fund and its management company, and includes the review of:
• periodic sustainability reporting and responsible investment disclosures produced by LBP AM;
• the Master Fund’s pre-contractual and periodic SFDR disclosures;
• information provided by LBP AM on an ongoing basis pursuant to the Master-Feeder Agreement; and
• any material changes to the Master Fund’s ESG framework, exclusion policies, or investment strategy notified by LBP AM.
Where the AIFM identifies any concern regarding the Master Fund’s continued alignment with the Feeder Fund’s environmental and social characteristics, it will engage with LBP AM to seek clarification or, where necessary, appropriate remedial action.
7. METHODOLOGIES
Sustainability Indicators
The sustainability indicator used to measure the attainment of the environmental and social characteristics promoted by the Feeder Fund is applied at the level of the underlying investment fund management companies.
Binding sustainability indicator-
ESG rating of third-party management companies whose investment funds are invested in by the Master Fund.
The sustainability indicator used is the number of third-party management companies with an ESG rating below “B”.
The ESG rating scale is assigned by the Master Fund Management Company's proprietary rating methodology comprising eight scores: A+, A, A-, B+, B, B-, C and D (with A+ being the highest and D the lowest).
Do No Significant Harm (DNSH)
The assessment of whether sustainable investments do not cause significant harm to environmental or social objectives is carried out by the management companies of the underlying investment funds.
The Master Fund management company ensures that the methodologies applied by underlying investment funds appropriately integrate controls for potential significant harm to other environmental or social objectives.
Principal Adverse Impacts on Sustainability Factors
The Feeder Fund considers principal adverse impacts on sustainability factors within the meaning of SFDR.
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For investments in investment funds managed by the Master Fund management company, principal adverse impacts are considered through:
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The application of ESG-based exclusions; and
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ESG analysis applied during investment selection and portfolio monitoring.
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For investments in investment funds managed by third-party management companies, preference is given to investment funds that implement a responsible or sustainable investment approach compatible with the ESG philosophy of the Master Fund management company.
The Feeder Fund does not itself calculate principal adverse impact indicators. The consideration of principal adverse impacts is carried out at the level of the underlying investment funds in accordance with their respective methodologies.
Further information on the consideration of principal adverse impacts is available in:-
The Master Fund management company’s responsible investment reports; and
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The Feeder Fund’s annual report.
8. Data Sources and Processing
8.1. Data sources used to achieve each of the environmental or social characteristics promoted by the Financial Product :
The Master Fund Management Company applies a multi-source approach to ensure better coverage as well as a diversity of analytical perspectives. The selected suppliers are mainly the following: Bloomberg, CDC Biodiversité, CDP, Ethifinance, ISS ESG, LSEG, Moody's ESG and MSCI.
8.2. Measures taken to guarantee data quality :
The Master Fund Management Company systematically carries out qualitative and quantitative due diligence when adding a new supplier.
This due diligence is supplemented by statistical studies carried out periodically to identify inconsistencies between the indicators of different suppliers on the same subject. In particular, these analyses may lead to the disqualification of an indicator deemed irrelevant, or to the correction of biases arising from methodological differences.
8.3. Data processing methods :
Supplier data is integrated into a data processing tool developed by the Master Fund Management Company. This tool gathers and aggregates the data to provide a single set of data used to monitor the environmental or social characteristics of the Financial Product.
8.4. Proportion of data estimated :
The Master Fund Management Company is not currently in a position to assess precisely the proportion of data that is estimated. The latter is likely to be fairly substantial, given the broad spectrum of themes covered by the extra-financial analysis and the fact that a significant proportion of the data transmitted by suppliers is based on qualitative analyses or proxies, and that the data processing tool developed by the Master Fund Management Company performs a statistical reprocessing of the integrated data.
The proportion of measured data will increase with the gradual implementation of European regulations governing the publication of non-financial data by issuers.
9. Limitation to Methodologies and Data
The diversity of our investments made by the Master Fund means that they are unable to provide full coverage of the environmental and social characteristics of all the stocks in their portfolios, especially as some markets are not themselves covered by data providers, which means that they are unable to take full account of the contribution of each stock in our portfolio to the sustainability indicators used to measure achievement of environmental and social objectives. This is particularly the case for small caps and non-European issuers, which are not subject to the same regulatory transparency constraints.
The Master Fund Management Company responds to these difficulties by diversifying data suppliers ("multi-source" approach).
The quantity of data handled does not allow for quality control on a case-by-case basis. The Master Fund Management Company therefore favors two approaches: (i) control of the rating methodology applied by data suppliers, and (ii) statistical control of the data as a whole. In addition, the "multi-source" approach applied by the Master Fund Management Company tends to smooth out potential individual assessment errors by data providers.
In addition, the absence of data on certain indicators used to verify that the environmental or social characteristics promoted are indeed achieved is compensated for by the use of other indicators on similar themes, as well as by a control of controversies affecting the issuer in question.
10. Due Diligence
The consideration of environmental and social characteristics and principal adverse impacts is based on the due diligence carried out by the management companies of the underlying investment funds in which the Master Fund invests. This due diligence includes the assessment of ESG policies, governance frameworks, exclusion policies, and the integration of sustainability risks and principal adverse impact indicators by the underlying investment fund managers. The Master Fund Management Company ensures that the methodologies applied by the underlying investment funds are sufficiently robust and consistent with the environmental and/or social characteristics promoted by the Feeder Fund.
In addition, prior to and on an ongoing basis, the AIFM carries out due diligence on the Master Fund and its management company in relation to the integration of environmental and social characteristics.
This due diligence includes an assessment of the Master Fund’s investment strategy, ESG framework, exclusion policies, sustainability risk integration, SFDR classification and disclosures, as well as the governance and organisational arrangements supporting the promotion of environmental and/or social characteristics.
The AIFM also monitors, on an ongoing basis, the continued alignment of the Master Fund with the environmental and/or social characteristics promoted by the Feeder Fund, including through the review of periodic reporting, responsible investment disclosures and other information provided by the Master Fund Management Company.
11. Engagement Policies
The Feeder Fund does not engage directly with investee companies. Engagement activities, where applicable, are carried out by the management companies of the underlying investment funds in which the Master Fund invests. The Master Fund Management Company assesses the existence and effectiveness of engagement practices applied by the underlying investment fund managers as part of its ESG due diligence.
12. Designated Reference Benchmark
No index has been designated as a reference benchmark to determine whether the Feeder Fund is aligned with the environmental or social characteristics it promotes.
13. EU Taxonomy Alignment
The Feeder Fund promotes environmental and/or social characteristics and is committed to partially making sustainable investments with an environmental or social objective.
However, the Feeder Fund does not commit to making a minimum proportion of sustainable investments with an environmental objective aligned with the EU Taxonomy.
The methodology applied by the Management Company does not allow the contribution of investments to be measured according to the definition of the European Taxonomy.
Under these conditions, the minimum proportion of sustainable investments with an environmental objective aligned with the EU Taxonomy is 0% of total investments.
The Feeder Fund does not invest in fossil gas and/or nuclear energy related activities that comply with the EU Taxonomy.
The Feeder Fund does not commit to a minimum proportion of investments in transitional and enabling activities.
14. Further Information
Additional product-specific sustainability information is available in the Feeder Fund’s prospectus and annual reports.-
SFDR Entity-Level Disclosure Statement
Sustainability Risk Policy and Principal Adverse Impact Statement
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Introduction
Titanbay Ireland Limited (the “Company”) is an alternative investment fund manager (“AIFM”) authorised and regulated by the Central Bank of Ireland pursuant to the European Union (Alternative Investment Fund Managers) Regulations 2013 (as amended) (the “AIFM Regulations”), including both Regulation 7(4)(a) and Regulation 7(4)(b)(iii) of the AIFM Regulations.
The Company is authorised to manage and distribute Luxembourg-domiciled alternative investment funds, including Reserved Alternative Investment Funds (“RAIFs”) and, in the future, may manage and distribute other fund vehicles such as undertakings for collective investment governed by Part II of the Luxembourg Law of 17 December 2010 on undertakings for collective investment (“UCI Part II Funds”). The Company is also authorised for MiFID Top-Up activities, notably Receipt and Transmission of Orders and Individual Portfolio Management.
As per 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, as amended (“SFDR”), the Company is defined as a “financial market participant” in respect of both its AIFM activities and its Individual Portfolio Management activities.
This Statement sets out the Company’s entity-level disclosures required under Articles 3 and 4 of SFDR. Information on how the Company’s remuneration policies are consistent with the integration of sustainability risks, as required by Article 5 of SFDR, is set out in the Company’s Remuneration Policy, which is published separately on the Company’s website.
2. Sustainability Risk Policy
2.1. Definition
For the purpose of this Statement, “sustainability risk” means 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. Examples include widespread flooding across parts of the UK or high workforce turnover as a result of poor employment practices.
This Statement has been established pursuant to Article 3 of SFDR and Commission Delegated Regulation (EU) 2021/1255 (“CDR 2021/1255”), which requires financial market participants to publish information about their policies on the integration of sustainability risks in their investment decision-making process.
2.2 Integration of Sustainability Risks into Investment Decision-Making
The Company has established, implemented and maintains this Sustainability Risk Policy in a manner proportionate to the nature, scale and complexity of its activities and consistent with the risk profiles of the financial products it manages.
The Company integrates sustainability risks into its investment decision-making process at all relevant stages, including:
• Investment due diligence: The Company considers sustainability risks when researching potential investments. This includes reviewing a target fund investment’s ESG policies, processes and governance practices, enabling the Company to identify investment opportunities consistent with its investment policy and with strong potential for long-term financial performance.
• Investment selection: The Company selects investments in target fund investments based on a holistic assessment of both financial and sustainability factors, and assesses the potential impact of sustainability risks on expected returns.
The Company has the option to leverage external specialists and/or partners to perform enhanced ESG due diligence on prospective target funds. The Company has enhanced its existing risk management frameworks to account for the integration of sustainability risks into investment decision-making.
The Company ensures that disclosures made in pre-contractual documents are consistent with the investment objectives of the financial products it manages.
2.3. Governance
The Designated Person for Investment Management is responsible for ensuring all investments are in line with the Company’s sustainability obligations. The Chief Risk Officer is responsible for reviewing this Statement.
3. Principal Adverse Impact Statement
3.1. Entity-Level Position
In accordance with Article 4(1)(b) of SFDR, the Company does not currently consider principal adverse impacts (“PAIs”) of investment decisions on sustainability factors at entity level. The Company has fewer than 500 employees and is therefore not subject to the mandatory PAI consideration obligation under Article 4(3) of SFDR. This Statement applies solely to the Company’s entity-level assessment and reporting obligations under SFDR.
3.2. Reasons for Not Considering Principal Adverse Impacts at Entity Level
The Company has determined that it is not appropriate, at this time, to consider PAIs at entity level for the following reasons:
• The legal and technical requirements for identifying, measuring, aggregating, weighting and mitigating PAI indicators under Commission Delegated Regulation (EU) 2022/1288 are complex, prescriptive and continue to evolve.
• The availability, quality and comparability of the data required to assess PAIs, particularly in the context of private markets and private equity fund investments, remain limited.
• In many cases, the relevant data may be incomplete, estimated, based on assumptions, or otherwise not sufficiently reliable to support a robust and consistent entity-level assessment.
• Given the nature of the Company’s investment activities, including investments made through underlying funds managed by third-party managers, the Company does not currently have direct and consistent access to the data required to perform meaningful entity-level PAI calculations.
Accordingly, the Company considers that an entity-level assessment of PAIs would not, at present, provide an accurate or reliable representation of sustainability impacts.
3.3. Product-Level Consideration of Principal Adverse Impacts
The Company’s decision not to consider PAIs at entity level does not preclude certain financial products managed by the Company from considering PAIs at product level.
Where a financial product considers PAIs on sustainability factors, this is disclosed at product level in accordance with Article 7 of SFDR and the applicable regulatory technical standards, including in pre-contractual and website disclosures.
3.4. EU Taxonomy
At entity level, the Company does not take into account the EU criteria for environmentally sustainable economic activities as set out in Regulation (EU) 2020/852 (the “Taxonomy Regulation”) for the purposes of assessing PAIs.
Any information relating to Taxonomy alignment, or the lack thereof, is disclosed at product level where required.
4. Remuneration Policy (Article 5, SFDR)
Information on how the Company’s remuneration policies are consistent with the integration of sustainability risks, as required by Article 5 of SFDR, is set out in the Company’s Remuneration Policy, which is published on the Company’s website.
5. Review and Future Consideration
This Statement is subject to at least annual review and approval by the Board of Directors. The Company will continue to monitor regulatory developments, supervisory guidance, data availability and market practices.
The Company will reassess its position on the consideration of PAIs at entity level if and when it considers that the necessary data, methodologies and regulatory clarity are sufficiently developed to support a robust and proportionate assessment.
6. Further Information
For further information regarding this Statement, please contact: compliance@titanbay.ie.
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LONDON, UK
Third Floor, Elsley House, 20/30 Great Titchfield Street, W1W 8BF
DUBLIN, IRELAND
26/27 Pembroke Street Upper, Dublin, D02 F5Y6
LUXEMBOURG
9, rue de Bitbourg,
L-1273 Luxembourg,
Grand Duchy of Luxembourg