Symbiotics SA (Symbiotics) is a Swiss Asset Manager, licensed by the Swiss Financial Market Supervisory Authority (FINMA) and focused on microfinance and impact investment services. Symbiotics acts as both a financial market participant and a financial advisor to several funds and sustainability is in the DNA of our company.

Symbiotics is committed to transparently communicating how we engage with environmental, social and governance (ESG) standards and how we use targeted impact strategies in order to contribute to the sustainable impact of the funds and sub-funds we manage and advise (the Funds). Therefore, the Funds and Symbiotics are aligned with the requirements of the European Union’s Sustainable Finance Disclosure Regulation (SFDR) (EU 2019/2088) for sustainability‐related disclosures in the financial services sector.


Sustainable Finance Disclosure Regulation (SFDR)
The SFDR (EU 2019/2088 Sustainable Finance Disclosure Regulation) requires (1) financial actors to categorize their products based on each product’s level of sustainability and (2) prove why and how this level is achieved. More specifically, the SFDR requires financial actors to disclose the integration of sustainability risks, the consideration of principal adverse impacts, and the promotion of sustainable investment objectives, if any, along with other specific disclosures.

Regulatory Technical Standards (RTS)
RTS, developed by European supervisory authorities (ESAs) and disclosed by the European Securities and Markets Authority (ESMA), bring clarity and specificity to the SFDR with additional content and detailed methodologies.

Sustainability Factors/ Environmental, Social and Governance (ESG) Factors/ Environmental and Social (E&S) Factors
These factors, refer, according to SFDR article 2 (24), to the Environmental and Social (E&S) Factors (e.g., employee matters, respect for human rights) that should be considered prior to an investment. By extension, Sustainability Factors also take governance-related issues (e.g., corruption and bribery) into consideration (with E&S Factors, these are ESG Factors).

Sustainability Risks
According to SFDR Article 2 (22), a Sustainability Risk is 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 the investment.

Principal Adverse Sustainability Impacts (PASI)/Principal Adverse Impacts (PAI)
A PAI is a negative effect that an investment may have on Sustainability Factors (e.g., adverse impacts on the physical, natural or cultural environment and on surrounding community and workers resulting from the business activity supported by an investment). PAIs are commonly used to explain the set of quantitative indicators (e.g., greenhouse gas emissions) to be disclosed according to SFDR, at an aggregated level as described in the RTS.

Target Investee
The emerging market borrowers that Symbiotics SA finances through the collective investment schemes it manages and advises are further defined in each collective investment scheme’s prospectus according to each investment strategy.

Capitalized terms in the following disclosures shall have the meanings found in the list of definitions of the document or integrated within this disclosure statement (“Disclosure”).


Symbiotics SA’s investment strategy and purpose is to have a material positive impact on society – and the environment – while mainly investing in microfinance, small and medium enterprise (SME) banking and impact finance markets through private debt strategies and impact bonds in emerging and frontier economies.
Over time, it has also increased its attention to the Sustainability Risks that could deteriorate the value of its investments and to the adverse impacts its investments could have on the environment and other stakeholders – also possibly deteriorating, in the end, the value of the investments – while focusing on doing good on some specific topics.
This Disclosure focuses on explaining how Symbiotics considers the potential adverse impact on Sustainability Factors and on the value of the investment – either in the short term (e.g., reputation) or in the long term (e.g., discontinuity of operations).
It thus does not focus on the way Symbiotics manages the positive impacts of investments on Sustainability Factors.


The first step in Symbiotics SA’s consideration of Sustainability Risks consists of excluding sectors and activities with high Sustainability Risks from the investment scope.
The collective investment schemes managed and advised by Symbiotics SA do not finance potential Target Investees involved in the following activities or projects:

  • Production or trade in any product or activity deemed illegal under host country laws or regulations or international conventions and agreements, or subject to international bans, such as pharmaceuticals, pesticides/herbicides, ozone depleting substances, PCB’s (polychlorinated biphenyls), wildlife or products regulated under CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora);
  • Production or trade in weapons and munitions;
  • Production or trade in alcoholic beverages (excluding beer and wine);
  • Production or trade in tobacco;
  • Gambling, casinos and equivalent enterprises;
  • Production or trade in radioactive materials; this does not apply to the purchase of medical equipment, quality control (measurement) equipment and any equipment where the Lender considers the radioactive source to be trivial and/or adequately shielded;
  • Production or trade in unbonded asbestos fibers; this does not apply to purchase and use of bonded asbestos cement sheeting where the asbestos content is less than 20%;
  • Drift net fishing in the marine environment using nets in excess of 2.5 km in length;
  • Production or activities involving harmful or exploitative forms of forced labor/harmful child labor or any form of human trafficking;
  • Production, trade, storage or transport of significant volumes of hazardous chemicals, or commercial-scale usage of hazardous chemicals; hazardous chemicals include gasoline, kerosene and other petroleum products;
  • Production or activities that impinge on the lands owned, or claimed under adjudication, by Indigenous peoples, without full documented consent of such peoples;
  • Cross-border trade in waste and waste products, unless compliant with the Basel Convention and the underlying regulations;
  • Destruction of high conservation value areas;
  • Pornography and/or prostitution;
  • Racist and/or anti-democratic media.


The second step in Symbiotics SA’s consideration of Sustainability Risks involves, for a majority of Target Investees, a proprietary ESG rating tool (“the ESG Rating”). The ESG Rating, among other things, evaluates the level of their Sustainability Risks and their preparedness to manage them. More specifically, the ESG Rating assesses a Target Investee’s commitment to and capacity for sustainable development, the effectiveness of its systems and services in this area – including its Sustainability Risk management systems – as well as its results.
Via this ESG Rating, commitment to and capacity for sustainable development are evaluated against approximately one hundred (100) quantitative and qualitative indicators (“the Indicators”), categorized into seven dimensions with an assessment of both potential positive and negative impacts:

  • Social governance
  • Labor climate
  • Financial inclusion
  • Client protection
  • Product quality
  • Community engagement
  • Environment

Each Indicator falls within one of the above dimensions and is graded from 0 to 3 (0 = nonexistence or very poor, 3 = high quality or very good). Each indicator has a weight as per Symbiotics SA methodology. The Indicators are combined to obtain one of six grades. The highest grade signifies an extremely strong likelihood that the Target Investee contributes to sustainable development and an extremely low risk of having negative social impacts. The lowest grade signifies a very low likelihood of contributing to sustainable development and a very high risk of having negative social impacts. Additional characteristics of the ESG Rating are found in the section dedicated to SFDR Article 4 Disclosure.
The ESG Rating score is sanctioned by Symbiotics SA’s internal credit committee.
Symbiotics SA does not propose investment deals with a low ESG Rating score to the Investment Committee.

Validation process
Symbiotics SA’s Investment Analysts are in charge of the prospection of the Target Investees, which are primarily active in financial inclusion, small business finance, project and enterprise development, and impact finance in emerging and frontier economies.
Target Investee screening is done through a due diligence process. Symbiotics SA ensures that Investment Analysts have sufficient knowledge of global, regional and local markets, as well as local laws to properly perform these reviews.
They collect all the necessary information during the due diligence of the Target Investee, including ESG Factors. The analysis is based on records, systems, policies, field visits and business practices.
Due diligence is a fundamental part of the investment analysis. Investment Analysts perform the assessments on-site (when possible) and meet and interview key Target Investee staff.
The analysis of ESG Factors is an integral part of the due diligence conducted on potential Target Investees, both from an impact and risk perspective.
In addition to using Investment Analyst expertise, Symbiotics SA’s Market and Credit Risk (MCR) unit independently performs its own analysis and risk monitoring. The MCR team is also charged with ensuring that the methodologies for the assessment of the Target Investees are properly applied and ensures consistency in cross-regional assessments.


The construction of each portfolio managed or advised by Symbiotics SA is based on the investment strategy defined in each collective investment scheme’s prospectus and responds to the investors’ risk appetites. Different criteria are used to build each portfolio, including, but not limited to, Sustainability Risk appetite.
Conclusions of the assessment of the Sustainability Risk and expected positive impact are provided in the investment proposal dedicated to each collective investment scheme’s Investment Committee.
ESG Factors are considered alongside other financial and business indicators. Preference is given to investments that are expected to produce greater global social and environmental benefits, to the extent relevant, reasonable and practicable.


Symbiotics SA performs periodic monitoring of Target Investees to assess changes and reevaluates the level of Sustainability Risk taken. This happens through periodic rating updates of the ESG Rating of Target Investees.
In addition, Target Investees must report to Investment Analysts on a monthly or quarterly basis. To the extent possible, such reporting is verified and improved during regular on-site visits to the Target Investees. The Investment Analyst then reports the findings to MCR and then publishes key findings and updates for the relevant Portfolio Manager or Advisory Manager. MCR updates the credit risk rating (CRR) score.
Given the nature of its financing (debt), Symbiotics SA does not have a formal ESG engagement framework proposing improvement action plans to Target Investees and Investees. However, Investment Analysts build a strong relationship with them and discuss strategic topics, proposing non-binding improvement suggestions for now.


Third parties or third-party originators currently propose a minority of Symbiotics SA’s Target Investees, often through syndications. For those deals, an assessment of their ESG-related methodologies is undertaken to ensure their equivalence with Symbiotics SA’s ESG Rating.


Sustainability Risks to which the collective investment schemes may be subject are likely to have a limited impact on the value of each collective investment scheme’s investments because Symbiotics SA (i) takes measures to avoid investments that do not take into account Sustainability Factors and (ii) conducts periodic monitoring to ensure that Sustainability Factors will be met on an ongoing basis.
It shall be understood, however, that (i) the methods used to identify, analyze and mitigate Sustainability Risks are limited by the level of information currently available on Sustainability Factors, (ii) the monitoring of some criteria which refer to qualitative information makes the assessment more subjective, (iii) there is no guarantee that the information will be systematically available for all Target Investees, and (iv) Sustainability Factors constantly evolve, making the comparison exercise between the different ESG assessments more complex.



This section describes, as required under SFDR Article 4, how the PAIs of investment decisions are considered throughout the investment process.
This statement refers to the year ended December 2021 and shall be updated annually.


The PAI indicators as referred in Annex I of the RTS shall be provided, mostly in a narrative manner, for the first year of reporting by the end of June 2022 for the year 2021, if there is no further delay in its implementation.


The processes and tools used to identify and prioritize PAIs, and to consider them in investment decision-making, are defined and described in Symbiotics SA’s Sustainability Policy, which is reviewed and approved periodically.

  • As described in the “Integration of Sustainability Risks into the investment decision-making process” section of this Disclosure, the teams involved in the identification and prioritization of PAIs are mainly:
    Investment Analysts who identify and prioritize risks depending on the context of the Target Investee (country, sector, size) and based on a due diligence of the practices and operations of each Target Investee.
  • Symbiotics SA’s Market and Credit Risk unit which sanctions the credit and ESG ratings, verifying that the methodologies to assess the Target Investee assessments are properly applied and ensuring consistency in the assessment’s cross regions.
  • The Portfolio team and, in particular, each collective investment scheme’s Investment Committee, which prioritizes risks according to their specific investment strategy and Sustainable Investment Objective(s) (as described in SFDR Article 9 on related disclosures).
  • An E&S Specialist, who supports these efforts as well.

Sources of information to identify (potential or effective) adverse impacts currently rely on answers from Target Investees, as they operate in regions where regulations do not always impose a high level of transparency and usually do not meet the minimum size criteria for such disclosure requirements. Despite the above, part of the Investment Analyst’s work is to be in regular communication with local associations, regulators and peers in order to ensure a good understanding of contextual risks.

  • The prioritization of Sustainability Risks that could materially negatively impact both the value of the investment and lead to adverse sustainability impact jointly or along different time horizons is also undertaken in the ESG Rating of the potential Target Investee:
    5-star rating: extremely strong likelihood of contributing to sustainable development/extremely low risk of having a negative social impact
  • 4-star rating: very strong likelihood of contributing to sustainable development/very low risk of having a negative social impact
  • 3-star rating: strong likelihood of contributing to sustainable development/low risk of having a negative social impact
  • 2-star rating: moderate likelihood of contributing to sustainable development/moderate risk of having a negative social impact
  • 1-star rating: low likelihood of contributing to sustainable development/high risk of having a negative social impact
  • 0-star rating: very low likelihood of contributing to sustainable development/very high risk of having a negative social impact.

As described previously and observed through this ESG Rating, the investment decision is based on both the level of PAI (evaluated through the Sustainability Risk assessment) and positive impact. These include both social and environmental criteria, with a strong weight on social dimensions given the sectors and objectives targeted, though the environmental criteria will be expanded upon in the coming years.

Part of the indicators or criteria assessed to identify Sustainability Risks and PAI, in parallel with the SFDR list of indicators, are the following:

The potential adverse risk or impact indicator E&S Source Additional source Calculation
Exposure to investments with prohibited or harmful activities E Target Investee No additional source
used up to now
Share of variable wage vs total
wage (measuring excess)
S Target Investee No additional source
used up to now
Turnover level (assessing
management of it if too high)
S Target Investee No additional source
used up to now
Average number of employees that departed the organization/average number of employees in a year
Human rights, land rights, indigenous peoples, cultural heritage threats,
resettlement (due to land acquisition)
S Target Investee No additional source
used up to now

The investment decision also takes into account the potential materialization of Sustainability Risks into adverse impacts, notably through monitoring.


No formal engagement policy and engagement monitoring system is in place. In case of important deficiency and/or occurrence of any adverse sustainability impact noticed either during due diligence or at the monitoring stage, the information is relayed to the relevant teams internally and the decision (e.g., non-renewal of the loan) made adequately.


The ESG Rating is partly based on the International Finance Corporation Performance Standards, which are broadly or partly based on other international standards such as the United Nations Guiding Principles on Business and Human Rights, International Bill of Human Rights, International Labour Organization Standards, and Equator Principles. The ESG Rating is not based on the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises as the collective investment schemes invest mostly in small to mid-size companies in emerging and frontier economies.

  • UN Guiding Principles on Business and Human Rights
    Broadly considered and adapted to the companies targeted
  • International Bill of Human Rights
    Broadly considered and adapted to the companies targeted
  • International Labor Organization Standards
    Broadly considered and adapted to the companies targeted
  • Equator Principles
    Broadly considered and adapted to the companies targeted
  • OECD Guidelines for Multinational Enterprises and Key considerations for banks implementing the OECD Guidelines for Multinational Enterprises
    Guidelines not applicable as the collective investment schemes invest mostly in small to mid-size companies in emerging markets.
    Note that all transversal standards, such as human rights, employment, environment, bribery, consumer interests, competition and taxation, are broadly considered and adapted to the companies targeted. Science and technology fall out of scope.
    All 6 measures of the key considerations for banks (considering partner lending institutions/microfinance institutions as concerned) are broadly covered by Symbiotics SA’s methodology or are planned to be.
    Measure 1: Embed responsible business conduct into policies and management systems
    Measure 2: Identify and assess actual and potential adverse impact
    Measure 3: Cease, prevent and mitigate adverse impacts
    Measure 4: Track implementation and results
    Measure 5: Communicate how impacts are addressed
    Measure 6: Provide for or cooperate in remediation when appropriate

For social stakes that are more specific to financial intermediation, Symbiotics SA’s ESG Rating is also inspired from the Cerise Alinus Social Performance Management tool, dealing notably with client protection.
All indicators are collected through, when applicable and practicable, on-site visits, meetings with the Target Investees, answers to specific questionnaires, and periodic data monitoring.


Symbiotics SA’s focus on responsible finance and ESG integration into its services flows into its corporate culture. Thus, Symbiotics SA’s remuneration practices are no different. They are designed in a manner that delivers long-term sustainability by (i) considering the long-term interests of investors, employees and shareholders by focusing on pay equality, market rates, and risk management, and (ii) not encouraging risk taking that is inconsistent with the risk profile of the collective investment schemes and that could lead to negative environmental and social impacts.
Compensation at an individual employee level consists of a fixed salary and potential additional financial incentives, such as bonuses at the sole discretion of Symbiotics SA, not indexed to volume of sales. Symbiotics SA pursues salary and remuneration standards that preclude any conflict of interest between its employees and the investors. In particular, Symbiotics SA refrains from providing any financial incentive for conduct that could damage investor interests. In addition, employees are required to comply with Symbiotics SA’s Conflict of Interest policy and Staff Regulations clauses pertaining to gifts and other benefits received from third parties. Symbiotics SA is also compliant with the Swiss Federal Act on Gender Equality, meaning that men and women in a similar position are paid equally, as measured and certified by an independent evaluator.