Disclaimer
HFR Asset Management
Sustainable Finance Disclosure Regulation (“SFDR”)
Waystone Management Company (IE) Limited
(the “Manager”)
HFR Asset Management, LLC
(the “Investment Manager”)
HFReu Umbrella Trust
(the “Trust”)
Integration of Sustainability Risks into the Investment Decision-Making Process
The Manager has delegated the investment management function for the Trust to the Investment Manager. The Investment Manager has sub-delegated this function for each of the sub-funds within the Trust (each a “Fund” and together the “Funds”) to certain investment managers who undertake the investment decisions on behalf of the Funds (each a “Trading Manager”). Therefore, the Manager does not itself integrate sustainability risks into the investment decision-making process and instead relies on the relevant policies and processes of the Trading Managers.
Under SFDR, “sustainability risks” are defined as environmental, social or governance events or conditions that, if they occur, could cause a material negative impact on the value of an investment.
Neuberger Berman Europe Limited (“Neuberger”) is the Trading Manager for: HFReu US Equity ex Financial Bull Fund; HFReu US Equity ex Financial Bear Fund; HFReu Euro Equity ex Financial Bull Fund; HFReu Euro Equity ex Financial Bear Fund. A downloadable copy of Neuberger’s SFDR statement can be found on their website.
Trutino Capital Management, LLC (“Trutino”) is the Trading Manager for HFReu Proximus Fund (the “Proximus Fund”). Trutino regards sustainability risks as relevant. A significant portion of the Proximus Fund’s portfolio is comprised of developed markets government bonds and liquid financial derivative instruments. Currently, there is insufficient information available regarding these bonds and liquid financial derivative instruments which fulfill the environmental or social characteristics required for the investment strategy. Consequently, it is not possible at present for the Trading Manager to properly integrate such risks into the investment decision-making process relating to the Proximus Fund, due to the high proportion of developed markets government bonds and liquid financial derivative instruments in the portfolio. Therefore, until such time as there is adequate information available regarding developed markets government bonds and liquid financial derivative instruments which fulfill the social or environmental characteristics required for the investment strategy, the Trading Manager is unable to assess the likely impact of sustainability risks on the return of Proximus Fund.
Principal Adverse Impacts Statement
Given that the investment management function of the Funds is delegated to the Trading Managers, the Manager relies on the investment policies and processes of those Trading Managers and, therefore, does not itself consider the principal adverse impacts of investment decisions on sustainability factors. Under SFDR, “sustainability factors” are defined as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
Information on Neuberger’s approach to principal adverse impacts can be found on their website.
Trutino does not consider the principal adverse impacts of investment decisions on sustainability factors because data for Proximus Fund’s investment universe of liquid developed markets government bonds and financial derivative instruments are not available.
Remuneration and Sustainability Risks
The Investment Manager considers that the relevant remuneration policies in relation to SFDR are those of the Trading Managers. Neuberger has adopted remuneration policies consistent its regulatory obligations which promote sound and effective risk management and discourage risk taking, including, without limitation, with respect to sustainability risks. Information on Neuberger’s remuneration policies can be downloaded here.
The remuneration policy of Trutino is consistent with its approach to the integration of sustainability risks. Trutino has established policies and procedures in relation to remuneration which, in Trutino’s opinion, are proportionate and consistent with sound and effective risk management in respect of all relevant risks, and which are compliant with applicable requirements.
Download a Copy of This Disclosure
当社を騙る詐欺的勧誘にご注意ください
2025年（10月14日）
一般社団法人日本投資顧問業協会より、当社の関与するファンドへの投資勧誘や送金依頼を受けたというお問い合わせがあったとの情報提供を受けております。
当社の役員、従業員、関係者等が、個人のお客様に投資を勧誘したり、送金を依頼したりすることは決してありません。
これら勧誘に基づいて、送金や個人情報の提供をしないようご注意ください。
不審な勧誘等を受けられた場合は、金融庁、最寄りの警察署、警視庁相談センターなどへご 相談くださいますようお願いいたします。
金融庁 金融サービス利用者相談室
https://www.fsa.go.jp/receipt/soudansitu/index.html
電話：0570-050588
警視庁 総合相談センター
https://www.keishicho.metro.tokyo.lg.jp/sodan/madoguchi/sogo.html
電話：03-3501-0110 または #9910
Notice of Fraudulent Solicitation in the Name of Our Firm
October 14th, 2025
We have been informed by the Japan Investment Advisers Association that there have been inquiries from individuals regarding investment solicitations or requests for money transfers purportedly made in connection with our funds.
Please note that none of our officers, employees, or any persons related to our firm ever solicit investments from, or request money transfers from, individual investors.
We urge you not to respond to any such solicitations, not to remit any funds, and not to provide any personal information in response to these fraudulent approaches.
If you receive any suspicious solicitations or communications, please contact the relevant authorities, such as the Financial Services Agency of Japan, your local police station in Japan, or the Tokyo Metropolitan Police Department Consultation Center.
Financial Services Agency of Japan – Financial Services User Counseling Office
https://www.fsa.go.jp/receipt/soudansitu/index.html
Tel: +81 0570-050588
Tokyo Metropolitan Police Department – General Consultation Center
https://www.keishicho.metro.tokyo.lg.jp/sodan/madoguchi/sogo.html
Tel: +81 03-3501-0110 or #9910