Sustainability-related disclosures

Integration of sustainability risks (Article 3)

In accordance with its approved Sustainability Policy and the principles of responsible investment set out therein, the Management Company recognises the importance of sustainability factors for investment objects and their performance, which in turn affects the financial results of the Management Company. Sustainability factors are understood as environmental, social and employee matters, as well as respect for human rights and anti-corruption and anti-bribery matters. Sustainability risk is understood as an event or situation related to sustainability factors which, if it occurs, could cause an actual or potential material negative impact on the value of investments, the assets under management, the company's profit or its reputation.

Principal adverse sustainability impacts (Article 4)

The Management Company does not currently consider the principal adverse impacts of investment decisions on sustainability factors, as defined in Article 4 of Regulation (EU) 2019/2088.

This decision was taken having assessed the size, nature and scale of the Management Company's activities and the investment strategies of the collective investment undertakings under management: at present there is no sufficiently reliable, comparable and comprehensive data available on the impact of investment objects on sustainability factors that would allow the mandatory impact indicators to be assessed and disclosed consistently. The Management Company reviews this decision periodically and will update the information once sufficient data is available.

Remuneration policy and sustainability risk (Article 5)

The Management Company's remuneration policy is consistent with sound and effective management of risk, including sustainability risk, and does not encourage risk-taking that is inconsistent with the risk profile or the investment strategies of the collective investment undertakings under management.

The variable component of remuneration, if paid, is determined taking into account long-term performance results and compliance with internal policies, including the Sustainability Policy. The remuneration policy is reviewed at least once a year.