The Company recognizes that ESG risks could threaten the investments at both individual and portfolio level but, following article 6.1 and 6.2 of the SFDR, the Company deems sustainability risks not relevant and do not take them into account in its investment processes.
The Company advises its client, in accordance to the investor's pre-contractual documentation and the investor is not aimed at achieving long-term capital growth by integrating an ESG approach. In addition, having an ESG investment process may lead in the exclusion of securities in which the Company may typically advise on. As of to date, the investment on specific targets do not allow a clear definition of sustainability risks and may result in different approaches adopted by different Investment Advisors when integrating ESG and sustainability in its investment analysis process.

Consequently, following article 6 SFDR, the Company does not consider the PASI on ESG factors in the investment process because this does not fit in with any of the current investment strategies.

This situation may, however, change in the foreseeable future depending on the regulatory and/ or legal framework as well as the Company's business decisions. This situation may also change based on the regulatory framework.

The Company shall not be taking sustainability risk into account in its overall remuneration and hence does not constitute criteria for the assessment of both variable and fixed remuneration. Should the Company decide to take ESG Criteria in their investment process, the ESG Policy shall be updated.