No consideration of sustainability adverse impacts
The following is an extract from the Company’s ESG Policy:
The Company does not consider the adverse impacts of investment decisions on sustainability factors. The basis for this decision is described in further detail below.
Currently, there is no universally accepted framework or list of factors to consider to ensure that investments are sustainable which means that there is a lot of subjectivity and uncertainty when it comes to the accuracy and comparability of data. It is important to note that the legal and regulatory framework governing sustainable finance is still under development, in particular, the level 2 draft regulatory technical standards referred to in the SFDR. When this is finalised, the Company will reconsider its policy and procedures with respect to this matter.
Furthermore, ESG data readily available on third party data provider platforms is limited in relation to small and mid-cap companies, which make up the major share of the investment spectrum of client portfolios and which are inherent to the Company’s value investing approach.
The Company does not invest or invests limitedly in certain sectors or companies whose products, services or activities could be considered contrary to the current trends regarding the promotion of ESG criteria.
Should the approach to the consideration of sustainability factors and the related risks change, either following finalisation of the regulatory and legal framework, or based on decisions by the Company with regard to the investment policies of its clients then this Policy will be updated.