TCFD Entity Report 2025

This report is issued by Kirkoswald Capital Partners LLP.

Kirkoswald Capital Partners LLP is a UK limited liability partnership authorised and regulated by the UK Financial Conduct Authority ("FCA") which, with its affiliates (together, "Kirkoswald" or the "Firm") are an institutional Global Macro Asset Management firm. With risk management at its core, Kirkoswald aims to compound its investors’ capital by building portfolios in fixed income, currency, credit, commodity, and equity markets globally.

Kirkoswald invests across a range of products and asset classes, primarily focused on emerging markets, including fixed income, foreign exchange, credit, commodities and equities. Through a combination of continuous risk management and research capability driven by a global network of economists, strategist, and analysts, Kirkoswald aims to provide the insight needed to reduce risk and enhance returns.

Approach to climate and the TCFD

Kirkoswald recognises that climate change poses both risks and opportunities to its business and investments, and has taken steps to incorporate climate considerations into its processes and policies where relevant. This report sets out Kirkoswald’s disclosures in relation to the four pillars and eleven recommendations set out by the Task Force on Climate-Related Financial Disclosures ("TCFD"), and fulfils the requirements of the FCA’s ESG Sourcebook in relation to TCFD disclosure (ESG 2.1 Preparation of climate-related reports and ESG 2.2 TCFD entity report).

Governance

Kirkoswald’s Responsible Investment Committee is responsible for developing and overseeing the Firm’s responsible investment (“RI”) strategy. The RI Committee consists of senior individuals representing a range of business areas. The RI Committee has formal responsibility for Kirkoswald’s RI strategy, and for implementing initiatives at a firm and fund level. It meets at least twice a year.

Though Kirkoswald does not currently manage any RI labelled or classified products, sustainability risks and opportunities may be considered by different investment vehicles to the extent that they are relevant and material. As such, material climate-related issues may be raised and discussed by the RI Committee. If a sustainability-related issue is found to pose a significant risk to an investment, it may also be discussed by the Risk Committee. Should wider input from other parts of the Firm be required to assess the issue, then it may also be assessed by the Operating Committee, and for very significant issues, escalated to the Management Committee.

All staff are required to undertake RI and sustainability training annually, which covers climate related issues and the TCFD.

Kirkoswald’s delegation arrangements

While Kirkoswald is registered and regulated in several locations, climate related issues are considered at a group level and are not therefore considered specifically material or relevant to any intra-group delegation arrangements implemented by the Firm.

Strategy

Climate risks and opportunities in investments

Aligning with the definitions and descriptions of climate-related risks and opportunities set out in the TCFD framework, Kirkoswald considers how both physical and transition risks may impact the Firm and its investments. For example, where relevant and material to an asset class or investment type, Kirkoswald’s investment team may examine how both acute and chronic physical climate risks such as extreme weather and more frequent or intense flooding and drought events may impact agricultural commodity prices, as well as natural gas and crude oil prices across a range of timeframes relevant to the Firm’s investments, from the immediate to the longer term (i.e. months to years).

The investment team may also assess transition related climate issues, including the policy and legal, technology, market and reputational risks associated with the transition to a low carbon economy. For example, the investment team may consider how a global event like the Russian invasion of Ukraine might impact natural gas prices and thus Eurozone inflation. This information is used alongside a range of other data to inform the investment team’s models and ultimately, investment decision-making.

In summary, climate considerations and risks are amongst the information and data inputs identified during the investment and research process. Although climate related issues and risks are not currently researched in isolation, issues relating to climate may form part of the Firm’s wider investment analyses and macro-economic views if material and relevant to an investment.

Scenario analysis

Climate-related scenario analysis allows for the exploration of different potential outcomes and impacts from climate change. This information may help to plan and respond most effectively to a variety of possible scenarios relating to climate change.

Given the nature of the investment universe, Kirkoswald does not typically undertake climate specific scenario analysis. However, climate-related issues (such as environmental policy changes, weather related risks or geopolitical issues) may appear as part of wider scenario analyses. Further, if the Firm’s investment team believes climate-related risks are material to an investment, they would consider applying scenario analysis in the macro context.

Climate risks and opportunities in our operations

Apart from the responsible investment approach deployed within the investment process to the extent relevant, Kirkoswald believes it is important to operate its business in line with sound sustainability practices. As such, the Firm has implemented a range of sustainable business initiatives. The RI Committee is responsible for sustainability initiatives at the management group level and endeavours to enhance Kirkoswald’s sustainability culture. Initiatives across energy efficiency, waste, and travel are intended to minimise the Firm’s carbon footprint and environmental impact, reducing exposure to climate related risks, for example:

Risk Management

Kirkoswald has established policies and procedures to manage the risks inherent in the Firm’s business (operational risk) and the funds that it manages (portfolio risk).

Operational Risk Management

Operational risk management is the responsibility of all members of each business team and their team leaders for their respective vertical. The Firm’s Operating Committee oversees the development of the operational risk framework, shares information around operational risks, considers control framework enhancements and escalates issues or concerns to the Management Committee.

Operational risk is assessed independently from portfolio and market risk and encompasses all non-investment facets of the business. The Operating Committee oversees both implementation of new business projects as well as existing infrastructure with a mandate to identify and mitigate potential operational risks to the business. All material issues or concerns are escalated to the Management Committee for assessment and actioning, as required.

Compliance conducts various ongoing testing of existing policies and processes as part of its ongoing compliance monitoring program.

Portfolio Risk Management

The risk culture, one of disciplined risk management, is a fundamental part of managing the Firm’s portfolios. As the Firm follows a single-PM model, the Firm expects portfolio managers to act as their own primary risk managers, aided by on-desk risk management and the Quantitative Analytics team to independently quantify and monitor portfolio risks. The investment team and risk personnel communicate on a regular basis to discuss markets, positioning, and any outstanding questions or concerns.

The Risk Committee reviews the Firm’s investment performance and risk, and oversees the Firm’s overall risk management framework and its risk appetite, strategy, principles and policies.

The Firm holds formal Risk Committee meetings which bring together the investment and non-investment teams to discuss risk, performance, and any general concerns. Outside of that, the teams are in regular contact over the course of the day.

Kirkoswald does not currently assess specific climate related risks. To the extent that they become material and relevant to investments, the relevant individuals would assess them using the same approach employed to assess other portfolio related risks.

Kirkoswald does not currently collect data relating to the emissions associated with its investments due to the nature of its investment strategy and related materiality of those risks. Approximately 2-3% of trading volumes comprises asset classes (including equities and commodities) that would be relevant for climate related data analysis. Kirkoswald does not believe this constitutes a sufficiently material portion of trading volumes to warrant further assessment. Should this change in the future, the Firm would review and explore data options. Kirkoswald continues to monitor how its risk exposure evolves and is prepared to adjust its approach accordingly. Consequently, Kirkoswald has not yet set targets but the Firm is prepared to do so if and when climate related risks become material.

The disclosures set out in this report comply with the requirements set out in the FCA ESG Sourcebook including guidance set out in ESG 2.1 Preparation of climate-related reports and ESG 2.2 TCFD entity report.

David Gilbert, Chief Legal Officer