Pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial service sector (“SFDR”) we make the following disclosures:

 

Sustainability risks

We do not integrate sustainability risks in our investment decisions in a structural manner. (A sustainability risk in this context means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.) The reason for this is that the consideration of sustainability risks is not mandated by the investment policies agreed upon with our clients.

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Adverse impacts investment decisions on sustainability factors

 

In our investment process we not consider principal adverse impacts of investment decisions on sustainability factors. (Sustainability factor in this context means environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.) This because considering adverse impacts is not mandated by the investment policies agreed with our clients and because in our view it is not possible to establish what such principal adverse impacts might be.

 

Remuneration policy and sustainability risks

 

Our remuneration policy does not contain incentives for not taking into account sustainability risks.