
Principal and emerging risks and uncertainties continued
The Company is constantly alert to the possibility of
emerging risks. Once the Company identifies a new
risk, it will assess the likelihood and impact of that
risk and will discuss and agree appropriate strategies
to mitigate and/or manage it. Emerging risks are
listed in the Company’s risk register and managed
through discussion of their likelihood and impact at
Risk Committee meetings, Board meetings and Board
strategy days as appropriate. Should an emerging
risk be determined to have any potential impact on
the Company, appropriate mitigating measures and
controls are agreed. Earlier in the year, the rumoured
new US tariff policy was added to the risk register
as an emerging risk. Now that some of the specifics
of the policy are known, the risk has been moved to
the register under the geopolitical risk section and
portfolio screening and monitoring actions have been
undertaken by the Investment Adviser.
Recently, the independence of the Federal Reserve
and the Big Beautiful Bill are items that have been
added to our emerging risks list, along with multiple
geopolitical situations including the conflicts in Russia/
Ukraine, India/Pakistan and Israel/Palestine, US/Iran
nuclear talks and US territorial interest in Greenland
and Panama.
In general, the current isolationist America First policy
is being monitored closely to identify any new risks
emerging from a potential reordering of global political
and economic alliances and the loss of US soft power.
Whilst the Company recognises climate risk as an
investment theme, it is also identified as a broad risk
covering transitional and physical risks, the impact
and timing of which is uncertain. On the regulation
front, proposals on ongoing costs disclosure rules,
sustainability-related disclosures and UK ISA eligibility
criteria are areas of focus.
A detailed review of the main financial risks faced by
the Company, and how they are managed or mitigated,
is set out in note 5 to the Financial Statements.
Key risk: Legal structure
Changes to laws, regulations and tax rules governing
the structure employed by the Company to carry on its
business could impact the viability of the investment
strategy by reducing the returns available and/or limiting
the ability of investors to hold shares. The Company’s
AIFM, Investment Adviser, Administrator, Brokers, legal
advisers and accountants in place in the UK, Guernsey
and Luxembourg screen the market continually to identify
potential changes to local tax and regulatory rules that
may have an impact on the Company. The Board reviews
the structure on an ongoing basis and regularly engages
a third-party adviser to formally confirm the continued
suitability of the organisational structure put in place by the
Company to carry out its business. This year, following a
Board-led review of our tax structure, the governance of our
Luxembourg Subsidiary was improved by the engagement
of a new Luxembourg-based independent director with a
strong background in accounting and risk management.
Key risk: Service providers
The Company has no employees and must therefore rely
on the performance of third-party service providers. Failure
to carry out their obligations to the Company in accordance
with the terms of their appointments or the failure of their
systems and processes could impact the Company’s
performance. Due diligence is undertaken before contracts
are entered into. Thereafter, service provider oversight is
conducted through ongoing interaction with the Management
Engagement and Audit Committees, who review control
reports provided by service providers throughout the year.
At year end, the Management Engagement Committee
reviews each service provider’s overall performance, including
a review of the contractual terms upon which the service
providers perform their services.
Key risk: Cyber, IT failure, money
laundering, fraud
The Board remains vigilant to the prevalence and trajectory
of risks associated with cyber attacks, IT failures, money
laundering and fraud that could lead to reputational damage,
legal liability or financial losses due to disruption of the
Company’s continued operations, including the loss or release
of commercial or personal data into the public domain.
Aspecialist provider supports the IT environment for the Board
and ensures that the environment is managed and monitored,
and threats are mitigated. Priorto the engagement of all
key service providers, the Board seeks assurance regarding
the adequacy of the processes and the controls in place to
mitigate the risks associated with their service delivery to the
Company. The Board monitors the effectiveness of the internal
control environment of key service providers through the
provision of periodic reporting and formally through an annual
review process.
Key risk: Board governance
Failure to promote the sustainable success of the Company,
ensure that necessary resources and controls are in place,
and maintain an effective engagement with Shareholders
and service providers, while ensuring that the Company’s
own policies, practices and behaviours are aligned with its
purpose, values and strategy can impact the performance of
the Company. In response to market feedback and in pursuit of
continued improvement and enhanced reporting, the Company
has developed a stand-alone governance policy providing
a detailed and transparent outline of governance structures
andpolicies.
Over the course of the year, one Board member departed
for personal reasons. For each Board vacancy a formal and
rigorous search is undertaken, with careful consideration
given to the appropriate balance of skills, knowledge,
experience, independence, time availability and diversity. This
enables the Directors to discharge their respective duties and
responsibilities to a high standard and to contribute positively
to overall Board effectiveness. Board performance continues to
be evaluated by an independent third party on a regular basis.
The last review occurred in 2023. Going forward, to meet
the increasing demands on time, due to mounting risk and
regulatory control responsibilities, a decision has been taken
toincrease the Board from five to six Directors.
Key risk: Sustainability risk
Shareholders, regulators and the market in general are
increasingly focused on sustainability-related issues. Failing
to meet and maintain the standards and objectives set
by the Board on sustainability-related matters, report and
disclose as required under increasing applicable regulations
and directives, and screen and monitor investments to avoid
adding undesirable assets can lead to reputational damage,
legal liability and loss of income. The Company established the
ESG and Stakeholder Engagement Committee to promote the
Company’s stated sustainability objectives, monitor progress
and verify that reporting and disclosure requirements are being
met. At the portfolio level, sustainability considerations have
been fully integrated into the Investment Adviser’s screening,
underwriting and portfolio management processes. Actions
include the implementation of an independently audited ESG
scoring methodology designed to help evaluate individual
assets and track portfolio sustainability performance over
time. As there is increased scrutiny on climate risk, this year
additional work has been undertaken on climate scenarios,
which is being reported on in the Sustainability Report for the
first time this year.
Key risks continued Emerging risks
42 Sequoia Economic Infrastructure Income FundAnnual Report and Accounts 2025