Sustainability Related Disclosures

1. Sustainability Risk Policy

The EU Sustainable Finance Disclosure Regulation (EU) 2019/2088 (“SFDR”) lays down harmonized rules for financial market participants and financial advisers on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes and the provision of sustainability related information with respect to financial products. Fiduserve Asset Management Ltd ( the “Company”) as both a financial market participant and a financial adviser is obliged to disclose information to investors with regards to the integration of sustainability risks, the consideration of adverse sustainability impacts and the promotion of environmental or social characteristics, and sustainable investments in its investment decision making process.

1.1 Integration of Sustainability Risks in the Investment Decision-Making Process

As part of its investment decision-making process, the Company considers already identifiable investment risks such as credit risks, market risks, operational risks, liquidity risks, funding risks or reputational risks when conducting its due diligence. With the introduction of the SFDR, the Company recognizes the need and benefits of integrating sustainability risks in the investment decision-making process, and as such Environmental, Social and Governance (“ESG”) factors are gradually being considered, integrated and implemented in the Company’s broader investment decision-making process.

Currently the Company does not manage any funds that promote environmental or social characteristics nor have sustainable investments. The Company, however, under its bond strategy followed by institutional investors for portfolios managed under a discretionary portfolio mandate, has begun to consider sustainable investments and promote environmental and social characteristics. Sustainability risks will be assessed together with the already identifiable risk factors and form part of the risk assessment process performed by the Company for the funds and individual portfolios it currently manages, and as part of the provision of investment advisory services to clients where relevant and applicable. The Company will rely on information from external data providers when assessing the ESG factors, and despite performing a qualitative review will not be held responsible for the accuracy of the information obtained.

2. No Consideration of Sustainability Adverse Impacts

The Company, in its capacity as a financial market participant and financial adviser, does not consider the adverse impacts of investment decisions on sustainability factors within the meaning of Article 4(a) of the SFDR. The Company acknowledges that certain investments made on behalf of funds and individual portfolios it manages may be negatively impacted by sustainability risks and that sustainability risks may impair the value of the investments made. The Company, however, considers that for the funds and individual portfolios it currently manages and/or provides investment advice to, principle adverse impacts are either not relevant at the moment or there is currently no available, accessible, relevant and comparable data to perform an adverse impact assessment. In view of the fact that the SFDR Level 2 Regulatory Technical Standards are not yet in final form, the Company will closely monitor regulatory developments with respect to SFDR and will consider adopting principal adverse impacts of investment decisions on sustainability factors in the future in order to address as a minimum adverse impacts in relation to climate and the environment, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters, investments in sovereigns and supranationals, and investments in real estate assets.

3. Remuneration Policy

The Company’s remuneration policy does not encourage excessive risk taking including those in relation to sustainability risks and therefore does not expect to make any changes to its existing policy. The Company will monitor regulatory developments and will reconsider whether to apply any changes to its remuneration policy in the future.

The Company will ensure that the Sustainability-Related Disclosures are kept up to date and amendments will be published on its website.


Last updated: 31/10/2021