SFDR Policy

Sustainable Finance Disclosure Regulation (SFDR) Policy

The European Union Sustainable Finance Disclosure Regulation (EU) 2019/2088 (“SFDR”) requires financial market participants and financial advisers, such as Easternmed Asset Management Services Ltd (the “Company”), to provide 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 their investment decision making process. The cornerstone of the SFDR is the principle of double materiality: financial as well as sustainability, making it easier for end-investors to understand how ESG and sustainability factors are considered and integrated to their investments.

The company’s goal is to have its portfolio management services ESG-informed, adhering to a strong integration process and stewardship code. Responsible investment practices are constantly developing and evolving. New risks may arise, public opinion may change and new market standards may be introduced. The company’s sustainable investment framework will be reviewed and, if necessary, adjusted on a recurring basis to incorporate these changes.

Integration of sustainability risks in the investment decision-making process

(SFDR - Article 3 disclosure)

The Company as part of its investment decision-making process, and its risk management procedures, it carries out due diligence and monitors a spectrum of risk factors. The Company recognizes the need to consider integrating sustainability risk (environmental, social and governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material impact on the value of an investment) in its investment decision-making process.

Some examples of ESG risk factors are the following:

  • Environmental: Water and Air Pollution, Climate change, Ecosystem change, Unsustainable practices, Environmental remediation, Carbon Emissions, Resource depletion, Energy resources, Deforestation and Water Scarcity.
  • Social: These relate to human rights and risks in operating unethical and illegal working conditions – e.g. Data security and governance, Social cohesion and stability, Child and slave labour, Product safety, Health and safety practices, Gender and Diversity, Human rights.
  • Governance: includes transparency and integrity concerning, inter alia, Remuneration, Tax, Bribery and Corruption, board composition, lack of appropriate board oversight.

The Company has elected to consider ESG factors as part of its wider investment decision-making process. Sustainability risks will be assessed among several other risk factors, as part of the risk assessment performed by the Company for the funds it manages, and for the provision of portfolio management and advisory services to clients. When the Company will be assessing the ESG factors, it will rely on information from external data providers, and although a qualitative review is to be performed, the Company cannot be responsible for the accuracy of this data.

No consideration of sustainability adverse impacts

(SFDR - Article 4 disclosure)

Although the Company takes sustainability and ESG very seriously, it does not, at the present time, consider the adverse impact of sustainability factors in its investment decisions or investment advice since it considers that for the funds and portfolio strategies it currently manages or advices, principle adverse impacts are, either not relevant at the moment, or there is currently not available, accessible, relevant and comparable data to perform the adverse impact assessment.

The Company will continue to closely monitor regulatory developments with respect to SFDR and other applicable ESG-focused laws and regulations and will consider adopting the principal adverse impacts following the finalization of the SFDR Level 2 Regulatory Technical Standards (RTS).


Remuneration Policy

(SFDR - Article 5 disclosure) 

The Company currently does not expect to make any changes to its remuneration policy in relation to sustainability risks, as its remuneration policy in general does not encourage excessive risk taking, including risk taking in terms of sustainability risks. The Company will reconsider whether to apply any changes to its remuneration policy in the future, and the relevant policy as well as the Company’s website will be updated.