SFDR Disclosures

Article 4 SFDR – Adverse Sustainability Impacts (Entity-Level Disclosure)

The Fund Manager does not consider the adverse impacts of investment decisions on sustainability factors in the manner described under Article 4 SFDR. This decision is based on:

  • The small size of the Cooperative;
  • The absence of sufficient, reliable data; and
  • The disproportionate administrative burden and associated costs such reporting would entail for the organization.

Article 5 SFDR – Remuneration Policy and Sustainability Risks

The Fund Manager’s remuneration policies are aligned with market standards and do not promote excessive risk-taking. As such, they are consistent with the integration of sustainability risks.

Article 6 SFDR – Transparency on the Integration of Sustainability Risks

‍The Fund does not promote environmental or social characteristics (Article 8 SFDR),nor does it have a sustainable investment objective (Article 9 SFDR). Therefore, it falls under the scope of Article 6 SFDR.

In accordance with Article 6, the Fund Manager provides the following information regarding the integration of sustainability risks:

A “sustainability risk” refers to an environmental, social, or governance (ESG) event or condition that, if it occurs, could have an actual or potential material negative impact on the value of an investment.

While the Fund Manager acknowledges the relevance and potential impact of
sustainability risks on investment value, it has determined that, due to:

  • The limited size of the Cooperative;
  • The lack of sufficiently reliable sustainability data; and
  • The small scale of the Fund Manager's organization,

it is not proportionate to integrate these risks into investment decisions for the Cooperative or to assess and disclose their potential impacts on returns.

EU Taxonomy – Consideration of Environmentally Sustainable Activities

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities as defined by the EU Taxonomy Regulation.

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