Statements made in accordance to applicable provisions under Articles 3, 4 and 5 of the 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 (“Disclosure Regulation” or “SFDR”).
Integration of sustainability risks in investment decision‐making processes
Sustainability risks means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause actual or potential material negative impact on the value of the investment.
In line with the SFDR which entered into force on 10 March 2021, GMM Global Money Managers AIFM Ltd (“GMM”) considers where material sustainability risks when selecting investments as part of the overall risk assessment of the Funds that GMM externally manages.
GMM acknowledges that when sustainability risks occur, there may be negative impact on an assets value and therefore this could have a material impact on the Net Asset Value of the Funds under management.
No consideration of sustainability adverse impact
Principal adverse impacts on sustainability factors refer to adverse impacts of investment decisions on sustainability factors that mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
In accordance with the discretion granted pursuant to the SFDR, GMM does not consider the adverse impacts of investment decision on sustainability factors in respect of the Fund(s) under management as the Investment Strategies of the Funds(s) under management do not regard sustainability factors to be material to their investment strategy. In the event that sustainability factors do, in the future, become material, the Manager will consider the principal adverse impacts of its investment decisions on sustainability factors.
Remuneration policy and the integration of sustainability risks
GMM does not encourage or reward an excessive assumption of sustainability risks according to its remuneration policy. The said policy is consistent with the integration of sustainability risks.