Policies on the Integration of Sustainability Risks

Sustainability Risk Policy

In line with the requirements imposed on in-scope financial market participants, the Company has formulated its Sustainability Risk Policy outlining the approach that the Company will take to integrating ESG considerations into its investment management processes by assessing not only all relevant financial risks but also relevant sustainability risks, with a view to mitigating risks and enhancing returns over the medium to long-term.

The Company defines Sustainability risk as an environmental, social or governance event or condition that, if it occurs, would cause an actual or a potential material negative impact on the value of the investment. Accordingly, sustainability risks are classified under three main pillars:

• Environmental factors such as climate change, pollution, resource use efficiency, protection of biodiversity and natural resource management, carbon emissions and air quality, deforestation etc;
• Social factors such as inequality, inclusiveness, employee relations, human rights, appropriate remuneration, fair working conditions, protection of cultural heritage etc; and
• Governance factors including management structures, executive remuneration, bribery and corruption, tax honesty, financial transparency etc.

ESG Integration

The Company describes its ESG integration approach as the systematic and explicit inclusion of material ESG factors into investment analysis and investment decisions. Such approach could span the breadth of the investment process - from identification of trends, analysis of investments through to portfolio construction.

Screening

The Company applies a set of filters for the purpose of determining which companies, sectors or activities are eligible or ineligible to be invested in based on its preferences, values and, or ethics. The Company could implement a mix of positive and negative screens in accordance with ethical inclusion or exclusion criteria. Once invested in, the on-going eligibility of said companies, sectors or activities is likely to be revisited on a periodic basis, or if there are significant changes.

After an extensive analysis, the Company has determined that sustainability risks are not relevant to the value of the investments of its current portfolios under management.

The Sustainability Risk Policy will be reviewed at least once a year to measure success and determine whether it continues to reflect the Company’s investment beliefs

Remuneration Policy

The Company’s approach to remuneration does not encourage excessive risk-taking with respect to sustainability risks.

Principal Adverse Impacts

No consideration of sustainability adverse impacts

The Company is currently appointed as manager for two collective investment schemes (each a “Fund” and collectively the “Funds”). Presently, when making investment decisions the Company does not consider the adverse impacts of its investment decisions on sustainability factors in terms of the SFDR as this is not relevant to: (1) the composition of the Funds’ portfolio; and (2) the investment strategies and/or policies of its Funds. The Company may possibly consider such adverse impacts in respect of future mandates in line with its Sustainability Risk Policy.