Disclosures of information on sustainability and adverse sustainability impacts in accordance with Regulation (EU) 2019/2088 (SFDR)
In the context of achieving the objectives of the Paris Agreement, the Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector, as in force, seeks to achieve more transparency regarding how financial market participants integrate sustainability risks in their processes on their investment decisions and investment advice and lays down rules on the assessment of adverse sustainability impacts and the provision of sustainability‐related information with respect to financial products.
Pursuant to the requirements of the Regulation (EU) 2019/2088 (SFDR), ALPHA TRUST-ANDROMEDA Investment Trust S.A. (hereafter the “Company” is obliged to disclose the manner in which sustainability risks are integrated into the investment process and the results of the assessment of the likely impacts of sustainability risks on its returns.
As the Company has delegated the portfolio and risk management to ALPHA TRUST MUTUAL FUND AND ALTERNATIVE INVESTMENT FUND MANAGEMENT S.A. (hereafter ALPHA TRUST), it relies on the application of the ALPHA TRUST Sustainability Risk Policy.
As such, the Company has adopted the portfolio Manager’s , ALPHA TRUST, policy on the integration of sustainability risks.
Information on the Integration of sustainability risks in the investment process will be maintained on the ALPHA TRUST website (www.alphatrust.gr/en/).
ALPHA TRUST-ANDROMEDA Investment Trust S.A. does not promote environmental or social characteristics or a combination of those characteristics, nor has sustainable investment as its objective and therefore, does not fall within the scope of either Article 8 or Article 9 of Regulation (EU) 2019/2088.
Potential Impacts of the sustainability risks on the Performance of the Portfolio
The Company is required, under Article 4 of Regulation (EU) 2019/2088 (SFDR), to make certain disclosures on its website explaining whether it considers principal adverse impacts of investment decisions on sustainability factors. As the Company has delegated portfolio and risk management to ALPHA TRUST, the Company’s policy is to rely on the portfolio Manager’s, ALPHA TRUST, approach to considering the principal adverse impacts of investment decisions on sustainability factors. The relevant portfolio Manager’s, ALPHA TRUST, approach is summarised as follows:
ALPHA TRUST considers that given the diversification of investments, the sustainability risk appetite, and the materiality thresholds it has set in the Sustainability Risk Policy, the exposure to these risks is deemed non-significant, while at the same time being monitoring on a regular basis.
In any case, due to the high volatility of ESG factors and the inability to reconcile historical data with future situations, it cannot be ruled out that the impact of sustainability risks on the performance of the Mutual Fund may become - in certain circumstances - significant.
Transparency of Remuneration Policy in relation to the integration of sustainability risks
ALPHA TRUST-ANDROMEDA Investment Trust S.A. has established its Remuneration Policy according to the provisions of Law 4548/2018 and relevant legislative and regulatory provisions.
Τhe Remuneration Policy is consistent with and promotes sound and effective risk management – explicitly including sustainability risk.
Details of the Remuneration Policy will be maintained on the Company's website.
In addition, the portfolio Manager, ALPHA TRUST, has established and maintains Remuneration Policy in accordance with the provisions of Directive 2009/65/EU on UCITS and the Regulation supplementing Directive 2011/61/EU on AIFMs.
Τhe remuneration policy is consistent with and promotes sound and effective risk management – explicitly including sustainability risk – and does not encourage excessive risk‐taking and/or risk-taking which is inconsistent with the risk profiles, funds’ rules or instruments of incorporation of the UCITS and AIFs that ALPHA TRUST manages.
Details regarding the Remuneration Policy are disclosed on the ALPHA TRUST website (www.alphatrust.gr/en/).
ALPHA TRUST supports the Principles of Responsible Investment
ALPHA TRUST, recognising the importance of responsible investment decisions based on ESG criteria, joined the "Principles for Responsible Investment" (PRI) initiative as "Investment Manager Signatory" in 2020.
As a PRI signatory, ALPHA TRUST adopts the following principles of responsible investment:
- Incorporation of ESG issues into investment analysis and decision-making processes.
- Active ownership and incorporation of ESG issues into our ownership policies and practices.
- Seeking of appropriate disclosure on ESG issues by the entities in which the company invests.
- Promotion of acceptance and implementation of the Principles within the investment industry.
- Collaboration for the enhancement of the corporate effectiveness in the implementation of the principles.
- Submission of a Transparency Report regarding the activities and implementation progress of principles.