Sustainable Finance Disclosure Regulation (“SFDR”)

Calamatta Cuschieri Investment Management Ltd ("CCIM") is a Financial Market Participant (“FMP”) under the SFDR.  In accordance with the SFDR requirements CCIM, as an Investment Manager for Pension Schemes and UCITS Manager, is required to provide disclosures on how it considers sustainability risks and the impact of risks related to Environmental, Social and Corporate Governance ("ESG").

Definitions

Sustainability Risks: 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 investment.Sustainability Factors: are environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

Sustainable Investment: An investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators on the use of energy, renewable energy, raw materials, water and land, on the production of waste, and greenhouse gas emissions, or on its impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality or that fosters social cohesion, social integration and labour relations, or an investment in human capital or economically or socially disadvantaged communities, provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance

Sustainability Risks

CCIM manages the Schemes and the Sub-Funds in accordance with the investment strategies and policies, and within the parameters of the applicable investment restrictions, as set out in the Schemes’ Documents. The Investment Manager maintains an ESG Policy which integrates sustainability risks and opportunities into its research, analysis and investment decision-making processes, where, and to the extent, applicable. The ESG Policy forms an integral part of its investment process and seeks to mitigate ESG and sustainability risks by ensuring that the Investment Manager, always to the extent applicable and appropriate, invests in companies or assets that are operated in an environmentally responsible manner, with respect for human rights and labour rights and providing good, healthy and safe working conditions and promote good governance conduct, always in accordance with, and within the context of, the Schemes’ investment strategies and policies.
Potential risks are further identified in the due diligence process, by means of screening for ESG controversies or further ESG analysis as warranted in context of the specific investments and addressed for each investment on a case-by-case basis pursuant to the Investment Manager’s risk management framework and ESG Policy.

While sustainability risks will be integrated in the investment decision process, no one aspect, such as ESG ratings, would prevent the Investment Manager from making any investment. Consequently, the Investment Manager does not make investments decisions in respect of the Company and its Sub-Funds based on sustainability risks.

No consideration of sustainability adverse impacts

CCIM does not consider the adverse impacts of investment decisions on sustainability factors in respect of the Schemes it manages, for the reasons hereunder.

▪         The investment decisions are taken by the Investment Manager in accordance with the applicable investment strategies, policies and investment restrictions of the Schemes.  The investment strategies and restrictions are set out in the Scheme Documents, which are accessible on the respective websites.

▪         The Investment Manager prioritises the investment strategies and policies of the Schemes without further restrictions being posed by adverse impact considerations, as this is deemed to be in the best interest of the Schemes it manages and in order to not exclude investments which are aligned with the Schemes’ investment strategies and policies. 

▪         Any considerations made towards adverse impacts within the investment decision process, would require the availability and reliability of data to ensure a proper assessment.  There is presently insufficient data to ensure consistency and completeness to allow the full assessment of adverse impacts.  The Investment Manager will monitor and assess the availability of data, particularly upon further mandatory reporting coming into effect, with a view to consider whether to review its position on the consideration of the adverse impacts, if and to the extent that this would be applicable at the time to the investment strategies and policies of the Schemes it manages.

In view of the considerations set out above, CCIM applies the principle of not considering adverse impacts of investment decisions on sustainability factors.

The Investment Manager may consider principal adverse impacts in the future should there be changes to these aspects and provided overall prevailing circumstances permit. In such circumstances and conditions permitting, the Investment Manager may consider investment focused on companies or assets that are operated in an environmentally responsible manner, with respect for human rights and labour rights and providing good, healthy and safe working conditions and promote good governance conduct

Remuneration Policy

The SFDR requires CCIM to include in the remuneration policies information on how those policies are consistent with the integration of sustainability risks.

CCIM has a fixed remuneration strategy unless it is justified following a performance assessment based on quantitative and qualitative criteria on the entity and personal level. In this regard, CCIM views its remuneration structure to be consistent with the integration of sustainability risks.