Last updated: April 2026
Subject to the amendments to the Fund Manager Code of Conduct (FMCC) on the management and disclosure of climate-related risks issued by the Securities and Futures Commission of Hong Kong (“SFC”) in August 2021, RIME CAPITAL LIMITED (“RIME”, “we”) is required, under certain baseline requirements set out in the FMCC, to disclose its governance, investment management and risk management framework in relation to the assessment of climate-related risks in respect of the funds it manages (the “Funds”).
The purpose of this statement is to provide clients and investors under the Funds with information on RIME’s policy in identifying, assessing, managing and monitoring relevant and material climate-related risks applicable to investments within the relevant Funds.
RIME has not committed to achieve any firm-wide sustainable investment target; however, climate-related risks and potential economic losses due to climate change have become a systemic financial risk that is difficult to ignore. RIME will, in considering compliance with evolving regulatory requirements concerning climate, take into account such risks in its overall risk assessment when managing a Fund.
The board of directors of RIME CAPITAL LIMITED (the “Board”) is responsible for the overall oversight of the management of RIME, including the supervision of overall strategy and the management of climate-related risks in the Funds.
The Board’s responsibilities include, but are not limited to:
acting as central oversight for the management of climate impact to ensure climate risk considerations are factored into strategic planning and investment processes across the Funds;
reviewing, from time to time, the investment management process and risk management framework covering climate-related risks;
monitoring the implementation status of policies and the progress of managing climate-related risks, and ensuring that actions and responses to climate issues are proportionate; and
determining strategies for managing environmental impact with a focus on climate and monitoring overall fund performance and risk appetite.
RIME maintains an assessment framework that aims to identify relevant and material climate-related risks within the investments of the Funds.
Where most of the Funds do not have an investment objective expressly focused on green or sustainable investing, RIME defines the relevance of climate-related risks holistically, having regard to the investment strategy, investment horizon and asset class(es) of a particular Fund.
Where climate-related risks are considered relevant to a Fund’s investment strategy, RIME evaluates the materiality of those risks to the performance of the Fund’s investments using a combination of quantitative and qualitative metrics. This materiality assessment aims to identify sectors and geographical regions of the Funds’ investments that are more impacted by climate factors, drawing reference to, for example:
guidance from the Sustainability Accounting Standards Board on financial materiality;
global environmental-related indices based on academic research and issued by universities or similar institutions which rank sustainability across jurisdictions;
exposure to NACE “brown” sectors and high climate impact sectors, classified based on EC No. 1893/2006; and
weighted average carbon intensity measures generated from reported and estimated Scope 1 and Scope 2 greenhouse gas emissions data provided by available third-party service providers.
Data or reference used for assessments in connection with a Fund will depend on data availability and, for any quantitative data adopted (where applicable), the calculation methodology of the relevant third-party service provider. RIME does not guarantee the accuracy or completeness of any such assessment and any assessment will be performed on a best-effort basis.
To the extent climate-related risks are considered relevant and material to a Fund, RIME will incorporate climate risk considerations into the investment analysis and security selection process. Depending on the strategy implemented, the Fund may, among other things, consider investee companies’ climate goals and policies and assess, from an overall perspective, whether there are potential future performance impacts arising from climate-related factors. Where climate-related risks are considered not relevant or not material to a Fund, RIME will perform periodic reassessments to re-evaluate the relevance and materiality of climate-related risks to that Fund.
RIME may consider deploying a portfolio action plan to mitigate climate-related threats that may impact the operations and business of investment targets in each of the Funds. The aim is to integrate such risks into the annual strategy review and capital allocation decisions. Regular monitoring and updates on climate-related market trends and regulatory requirements help ensure sufficient incorporation of climate risk factors into the Funds’ investment decision-making processes.
For investments in sectors categorised as having high climate-related risks, such as those in carbon-intensive industries, RIME will engage with the designated portfolio manager(s) to understand the rationale behind the investment decision and determine whether proceeding with such investment is consistent with the Fund’s risk appetite. This will be followed by an evaluation of relevant mitigation plans to address climate-related risks associated with such investments.
Fund-specific climate-related information may be provided to investors in a particular Fund, on request and subject to data availability for reference.
