EU introduced under the Sustainable Action Plan a series of new legislative measures which connect finance with sustainability.

Key regulation includes a classification system for sustainable activities (Taxonomy) and the mandatory disclosures and labels for green financial products (SFDR).

Pursuant to this commitment, we are gradually integrating Environmental, Social and Governance (ESG) metrics in our investment process in different asset classes with the goal to minimize risks, improve financial returns and at the same time have a quantifiable improved ESG footprint. The applicability of the standards and of the analysis may vary depending on the type of the managed portfolio, the asset class, the region, the instrument used, the mandate and possible specific client instructions as well as the type of services provided. (i.e Advisory mandates, cash and cash equivalent are excluded as asset classes from ESG investment policy and strategy). Evaluating sustainability risk is challenging since many times scarcity of reliable data and the fact that relevance and materiality of sustainability factors vary across asset classes and securities.

Given the variance, currently we do not consider any specific adverse impacts of investment decisions on sustainability factors, as defined in Regulation (EU) 2019/2088 of 27 November 2019 and analysts are responsible for identifying sustainability-factor materiality, as well as any relevant timing, probability, and severity of sustainability-related risks.

As of today (March 2021), none of our managed portfolios pursue an investment strategy that promotes environmental or social characteristics or has a sustainable investment objective as defined in Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (SFDR). In addition, we do not deem the investment decisions to have adverse impact on sustainability factors.

In case we decide in future, for any of the managed portfolios, to follow a strategy which promotes specific environmental or social characteristics or is in line with sustainable Investment objectives, the mandate will be updated according to the requirements of the SFDR and the investors will be duly informed and notified in advance.