Pursuant to EU Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (the "SFDR"), the financial market participants are required to disclose the manner in which Sustainability Risks (as defined hereafter) are integrated into their investment decision-making process and the results of their assessments of the likely impacts of Sustainability Risks on the returns of their financial products.
Sustainability risk is 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 the investments of the relevant financial product ("Sustainability Risk"). Such risk is principally linked to climate-related events resulting from climate change (the so-called physical risks) or to the society's response to climate change (the so-called transition risks), which may result in unanticipated losses that could affect the financial product's investments and financial conditions. Social events (e.g. inequality, inclusiveness, labour relations, investment in human capital, accident prevention, changing customer behaviour, etc.) or governance shortcomings (e.g. recurrent significant breach of international agreements, bribery issues, products quality and safety, selling practices, etc.) may also translate into Sustainability Risks.
As financial market participant, we do not follow a dedicated ESG investment strategy and do not integrate Sustainability Risks into our investment decision-making process. Sustainability is neither an objective, nor a determinative part of the investment process of our financial products. The investments underlying our financial products do not take into account the EU criteria for environmentally sustainable economic activities.
Transparency of remuneration policy in relation to the integration of Sustainability Risks Pursuant to Article 5 of SFDR, financial market participants shall include in their remuneration policies information on how those policies are consistent with the integration of Sustainability Risks.
Based on information above, as we do not follow a dedicated ESG investment strategy for our financial products, we have not established a relative renumeration policy in this regard.
Please note that our management does not consider the "principal adverse impacts", if any, of its investment decisions on sustainability factors, according to Article 4.1 (b) of the EU Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector.
This approach is based, amongst other factors, on the fact that we consider the identification and monitoring of principal adverse impact as not relevant in light of the strategies implemented by the product we manage.