Responsible Investment
Horizon Capital AG is committed to integrate Environmental, Social and Governance criteria in its investment process as we believe they are the key values over the long-term.
Horizon Capital AG is a registered signatory of the United Nations Principles for Responsible Investment.
Our Guiding Principles :
Use trade as a force for good
- International trade is powerful engine for inclusive economic growth, poverty reduction, food security and sustainable development
- The Asian Development Bank estimated a $1.7 trillion global trade finance gap
- At Horizon Capital, we help bridging the gap between lenders and borrowers in the natural resources industry
- SMEs account for 50% of employment worldwide
- Access to finance remains a major obstacle for SMEs
ESG Disclosures
Sub-Fund 1 – European Trade Finance
(Article 8 Product – Based Strictly on Prospectus Content)
SFDR ARTICLE 10 – WEBSITE DISCLOSURE
- Summary
Sub-Fund 1 promotes environmental and social characteristics in accordance with Article 8 SFDR. It invests in short-term trade finance transactions supporting small and medium-sized enterprises (SMEs) active in commodity trading. Through its investment strategy and exclusion lists, the Sub-Fund aims to promote inclusive economic growth (SDG 8), poverty reduction (SDG 1), and food security (SDG 2).
The Sub-Fund does not aim to make sustainable investments as defined under Article 2(17) SFDR. These characteristics are attained via ESG due diligence, commodity-level impact analysis, governance assessments, and monitoring in line with ICC sustainable trade finance guidelines.
- No sustainable investment objective
The Sub-Fund promotes environmental and social characteristics but does not pursue a sustainable investment objective and does not commit to making sustainable investments within the meaning of Article 2(17) SFDR.
- Environmental and social characteristics promoted
The Sub-Fund promotes:
Social & Development Characteristics
- Access to finance for SMEs in commodity trading
- Promotion of job creation and inclusive growth (SDG 8)
- Contribution to poverty reduction (SDG 1)
- Contribution to food security (SDG 2)
Environmental & Social Responsibility Characteristics
- Avoiding financing activities that undermine sustainability
- Screening of commodities with elevated environmental or social risks
- Limiting exposure to harmful sectors (e.g., fossil fuels)
- Investment strategy
The strategy focuses on short-term secured trade finance for commodities and essential goods. ESG integration includes:
- Lists of sectors and countries with high ESG risk.
- Borrower ESG due diligence based on ICC Guidelines for Sustainable Trade Finance.
- Review of internal sustainability policies, certifications, and governance.
- Commodity-level ex-ante impact analysis, based on NGO reports, academic papers, and industry sources.
Good governance is assessed through questionnaires, verification of compliance with standards, and supporting documentation.
- Proportion of investments
Category | Expected share |
Aligned with E/S characteristics | At least 51% |
Other investments | Maximum 49% |
Sustainable investments (Art. 2(17)) | 0% |
- Monitoring of characteristics
Monitoring includes:
- Annual ESG due diligence updates
- Monitoring compliance with exclusion lists
- Monitoring origins of trades and associated geographic risks
- Ongoing review of controversies and governance issues
- Verification of adherence to ICC standards
- Methodologies
- Internally developed ESG due diligence on each borrower following ICC Sustainable Trade Finance guidelines.
- Ex-ante environmental & social commodity assessment (risk identification through NGO/academic/industry sources).
- Sector and country limitations lists.
- Data sources and processing
Data sources include:
- Borrower questionnaires
- ESG documentation
- Independent certifications (when available)
- NGO reports, academic literature, and industry data
- Sanctions lists & international compliance databases
- Country-level ESG indices (Global Risk Profile ESG Index)
All data is qualitatively assessed by the investment team.
- Limitations to Data and Methodology
- SME borrowers often publish limited ESG information
- Commodity-level data varies by product and region
- ESG Index indicators depend on third-party availability
- Reliance on qualitative and external sources (NGO reports, literature)
- Limited formal sustainability reporting in emerging markets
- Due Diligence
Due diligence includes:
- ESG questionnaires
- KYC / AML / sanctions checks
- Commodity impact analysis
- Verification of compliance with exclusion lists
- Review of sustainability policies
- Independent certifications when obtainable
- Engagement Policies
The Sub-Fund does not exercise voting rights (credit strategy). Engagement occurs through:
- Information requests
- ESG improvement discussions
- Potential non-renewal of facilities in case of severe ESG breaches
- Imposing stricter documentation or standards when necessary
- Designated Reference Benchmark
None.
Sub-Fund 5 – “Resilient Trade Finance”
(Article 8 Product – Based Strictly on Prospectus Content)
ARTICLE 10 SFDR – WEBSITE DISCLOSURE
- Summary
Sub-Fund 5 promotes environmental and social characteristics in accordance with Article 8 SFDR. It invests in short-term trade finance transactions supporting small and medium-sized enterprises (SMEs) active in commodity trading. Through its investment strategy and exclusion lists, the Sub-Fund aims to promote inclusive economic growth (SDG 8), poverty reduction (SDG 1), and food security (SDG 2).
The Sub-Fund does not aim to make sustainable investments as defined under Article 2(17) SFDR. These characteristics are attained via ESG due diligence, commodity-level impact analysis, ESG-related exclusions, governance assessments, and monitoring in line with ICC sustainable trade finance guidelines.
- No sustainable investment objective
The Sub-Fund does not pursue a sustainable investment objective and will not make sustainable investments within the meaning of Article 2(17) SFDR.
- Environmental and social characteristics promoted
The Sub-Fund promotes:
Social & Development Characteristics
- Access to finance for SMEs in commodity trading
- Promotion of job creation and inclusive growth (SDG 8)
- Contribution to poverty reduction (SDG 1)
- Contribution to food security (SDG 2)
Environmental & Social Responsibility Characteristics
- Avoiding financing activities that undermine sustainability
- Screening of commodities with elevated environmental or social risks
- Exclusion of harmful sectors (e.g., fossil fuels)
- Investment strategy
The Sub-Fund invests in short-term trade finance across soft commodities, bio-chemicals, metals, and essential goods. ESG integration includes:
- Two binding exclusion lists (sector + countries with ESG risk score >64)
- ESG due diligence aligned with ICC sustainable trade finance guidelines
- Review of borrower sustainability policies and certifications
- Commodity impact analysis focusing on environmental and social risk identification
- Proportion of investments
Category | Expected share |
Aligned with E/S characteristics | 100% |
Other investments | 0% |
Sustainable investments (Art. 2(17)) | 0% |
- Monitoring of characteristics
- Annual ESG due diligence updates
- Monitoring compliance with exclusion lists
- Monitoring origins of trades and associated geographic risks
- Ongoing review of controversies and governance issues
- Verification of adherence to ICC standards
- Methodologies
- Internally developed ESG due diligence on each borrower following ICC Sustainable Trade Finance guidelines.
- Ex-ante environmental & social commodity assessment (risk identification through NGO/academic/industry sources).
- Sector and country limitations lists.
- Data Sources and Processing
Data sources include:
- Borrower questionnaires
- ESG documentation
- Independent certifications (when available)
- NGO reports, academic literature, and industry data
- Sanctions lists & international compliance databases
- Country-level ESG indices (Global Risk Profile ESG Index)
All data is qualitatively assessed by the investment team.
- Limitations
- SME borrowers often publish limited ESG information
- Commodity-level data varies by product and region
- ESG Index indicators depend on third-party availability
- Reliance on qualitative and external sources (NGO reports, literature)
- Limited formal sustainability reporting in emerging markets
- Due Diligence
Due diligence includes:
- ESG questionnaires
- KYC / AML / sanctions checks
- Commodity impact analysis
- Verification of compliance with exclusion lists
- Review of sustainability policies
- Independent certifications when obtainable
- Engagement Policies
The Sub-Fund does not exercise voting rights (credit strategy). Engagement occurs through:
- Information requests
- ESG improvement discussions
- Potential non-renewal of facilities in case of severe ESG breaches
- Imposing stricter documentation or standards when necessary
- Designated Reference Benchmark
None.
Exclusion Policy
We do not finance companies involved in :
- Precious metals
- Armament (conventional and controversial weapons)
- Gambling activities
- Facing severe and structural controversies
- Not compliant with UN Global Compact

1. Human Rights
Businesses should:
- Support and respect the protection of internationally proclaimed human rights
- Make sure that they are not complicit in human rights abuses

2. Labor Standards
Businesses should uphold:
- The freedom of association and the effective recognition of the right to collective bargaining
- The elimination of all forms of forced and compulsory labour
- The effective abolition of child labour
- The elimination of discrimination in respect of employment and occupation

3. Environment
Businesses should:
- Support a precautionary approach to environmental challenges
- Undertake initiatives to promote greater environmental responsibility
- Encourage the development and diffusion of environmentally friendly technologies

4. Anti-corruption
- Businesses should work against all forms of corruption, including extortion and bribery