Regulation (EU) 2019/2088 of 27th November 2019 on sustainability-related disclosures in the financial services sector, as amended (hereinafter the “SFDR”)governs the transparency requirements regarding the integration of sustainability risks into investment decisions, the examination of adverse impacts on sustainability and the disclosure of Environmental, Social and Governance (ESG) information and sustainability-related information. Commission Delegated Regulation (EU) 2022/1288 supplements the SFDR on the content and presentation of relevant disclosures. 

The Company provides the investment services of portfolio management and investment advice, therefore it falls under the definition of a financial market participant and a financial adviser, respectively, as per the SFDR, and as such, it has the relevant obligations set forth in this notification.

In general, the Company closely monitors the continuous developments in the changing regulatory framework and adapts its investment policy, in order to meet, not only the requirements of the supervisory authorities, but also the increased interest of investors for products and services with sustainable characteristics and goals.

It is noted that, currently, the Company is at the initial stages of incorporating sustainability risks into its investment decisions, and has started considering any negative impacts on sustainability. In particular, the Company has started taking into account ESG ratings of the entities that the Company invests or plans to invest in, to the extent that such information is available. 

Investments made by the Company do not, as things stand, take into account the EU classification criteria under the Taxonomy Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investments. 

If, in the future, it is decided that sustainability assessments will be further integrated into the investment analysis and decision-making process, in accordance with the SFDR, this notification will be updated accordingly.

No consideration of adverse impacts of investment decisions on sustainability factors As per Article 12 of Commission Delegated Regulation (EU) 2022/1288, the Company, in its capacity as a Financial Market Participant, for the time being, except as may be otherwise disclosed at a later stage on the Company’s website, does not consider principal adverse impacts of investment decisions on sustainability factors due to the fact that currently such considerations are not deemed material to the Company’s business decisions, taking into account the size of the Company and the nature, complexity and scope of the activities offered. The Company may reassess its consideration in the future in regards to adverse impacts on greenhouse gas emissions, biodiversity, water, waste, social and employee matters, amongst other sustainability factors.

No consideration of adverse impacts of investment advice on sustainability factors

As per Article 13 of Commission Delegated Regulation (EU) 2022/1288, the Company, in its capacity  as a Financial Adviser, for the time being, except as may otherwise be disclosed at a later stage on the Company’s website, does not consider principal adverse impacts of investment decisions on sustainability factors in its investment advice, taking account of the size of
the Company and the nature, complexity and scope of the activities offered and
the types of financial products that the Company advises on. The Company may
reassess its consideration in the future in regards to adverse impacts on
greenhouse gas emissions, biodiversity, water, waste, social and employee
matters, amongst other sustainability factors.

28 November 2023