Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector requires the Management Company to make certain disclosures on its website, including information on the Management Company’s policies on the integration of sustainability risks into its investment decision-making process; its approach to adverse sustainability impacts; and the consistency of its remuneration policies with the integration of sustainability risks.

Its objective is to provide end-investors with information on the integration of sustainability risks carried out by institutions.

Sustainability risk policies and integration of sustainability risks

As part of the evaluation of investments, the Management Company, through its managers, will consider, where appropriate, risks relevant to the sustainability of potential investments.

The Management Company endeavours to recognise, evaluate and appropriately weight all relevant risk factors when making investment decisions. Thus, sustainability risks are only one of several risk aspects considered as part of investment decision-making. Other risk factors considered could be (but are not limited to): market, liquidity and counterparty risks. ESG (environmental, social and governance) factors and risks are therefore taken into account in the investment decision-making process as an additional tool providing further information on current and potential non-financial risks of investments. It should therefore be understood in conjunction with the traditional and non-exclusive analysis of “sustainable investment”.

While the Management Company believes that sustainability risks could have an impact, positive or negative, on the performance of client portfolios, these impacts are not material given the management model followed within the Company.

In view of the above, the Management Company does not currently have specific sustainability risk policies, or other similar type of ESG policies, for its investments.

Adverse sustainability impacts are not considered.

The Management Company does not currently consider adverse impacts of its investment decisions on sustainability factors. This is due to the lack of sufficient and reliable sustainability-related information, which is particularly useful for the analysis of adverse impacts.


Consistency of remuneration policies

The Management Company considers that its remuneration policy is consistent with its approach to integrating sustainability risks into the investment decision-making process.

Sustainability risks are taken into account among other potentially relevant risk factors when making investment decisions and failure to take into account any of the relevant risks could have an adverse impact on investment performance. This, in turn, could have a negative impact on the financial performance of the Management Company.

In general, the Management Company and its remuneration policies are based on fixed and variable remuneration. Variable remuneration is determined on a discretionary basis and is strongly linked to the overall financial performance of the Management Company. Under this system, any failure to consider sustainability risks with an adverse impact on investment performance would be reflected in the level of overall variable remuneration awarded to staff. In addition, in this case, adverse performance is likely to impact variable remuneration at the individual level”.

Therefore, we consider that the remuneration structure is in line with both financial and non-financial risks.


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