Consideration of adverse sustainability impacts

Within the context of SFDR (Regulation 2019/2088 (EU)) we are unable to confirm that the fund considers adverse impacts of investment decisions on sustainability.

This is due to two reasons: i) quantifying adverse effects at this stage is difficult due to shortage of relevant sustainability data; ii) the regulation package for management of adverse impacts is very new and best practice is yet to develop.

Due to the above, we take potential adverse sustainability effects into account at a qualitative level. Should any adverse impacts occur during the holding period, we will evaluate the issue and take necessary action to mitigate it.

As regulation matures and best practices emerge, we will continue to evaluate our approach and update it accordingly.