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Sustainable Finance Disclosure Regulation

Information in accordance with Regulation (EU) 2019/2088 – Sustainable Finance Disclosure Regulation (“SFDR”) (also known as the Disclosure Regulation)

Introduction

Introduction

SFDR requires in-scope entities to disclose information about their policies on the integration of sustainability risks in their investment decision-making process. This EU-regulation lays down harmonised rules for “Financial Market Participants” and “Financial Advisors” 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.

Lansdowne Partners Austria GmbH (the “Firm”), due to its activities as a portfolio manager, is considered a Financial Market Participant and as such is subject to SFDR. The following statements comprise the Firm’s relevant SFDR disclosures.

The Firm endeavours to provide you with the information to be disclosed in a clear and comprehensible manner by means of this document. Should you have any questions or should there be any ambiguities, please do not hesitate to contact us at [email protected].

Our approach to sustainability risks

SFDR defines “sustainability risk” as an environmental, social or governance event or condition that, if it occurs, could cause negative material impact on the value of the investment.

As a professional provider of investment services, the Firm is aware of the relevance of these risks. The Firm’s investment teams have access to quantitative and qualitative information on sustainability risks and will generally take sustainability risks into account when making an investment decision. However, sustainability risk is one of many risks which may be relevant to a determination of risk, depending on the specific investment opportunity. Therefore, sustainability risk may not, by itself, prevent the Firm from making any investment on behalf of its clients.

Sustainability-compliant remuneration policy

The Firm maintains a remuneration policy which, inter alia, aims to prevent conflicts of interest in connection with the remuneration of its employees. It also conforms to the concept of sustainability – it does not contain any provisions that would contradict the Firm’s approach to sustainability and, in particular, its approach of taking into account sustainability risks.

Adverse sustainability impacts

In accordance with Article 4 of SFDR, the Firm has chosen not to consider adverse impacts of investment decisions on sustainability factors in the context of portfolio management or the provision of investment advice. “Sustainability factors” mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. These factors are of great importance to the Firm, but they will not be reported at Firm level. Currently no Fund managed by the Firm considers Principle Adverse Impacts. Reasons for this include the higher costs associated with effectively gathering, monitoring, and reporting this information. Dedicating existing resources to this task could furthermore have a negative material impact on the value of the investments. The Firm will monitor further developments at European level.