SFDR Disclosures

Strix Asset Management Limited (“Strix”)

Information required under the EU Sustainable Finance Disclosures Regulation (EU) 2019/2088 (the “SFDR”)

Article 3

Article 3 of SFDR the Sustainable Finance Disclosures Regulation (EU) 2019/2088 (“SFDR”) requires financial market participants to publish on their websites information about their policies on the integration of sustainability risks in their investment decision making process.

Sustainability Risks” as defined in Article 2(22) of SFDR is: “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 an investment”.

Sustainability Risks include (but are not limited to) the following:

• environmental risks such as the impact of environmental events such as increased flooding risks on operations of portfolio companies;
• social risks such as impact of non-compliance with anti-slavery or working conditions laws and regulation by portfolio companies; and

While Strix may integrate the consideration of Sustainability Risks into its investment decision  making process, the primary focus of the investment strategies of Strix are not the promotion of specific environmental or social characteristics.

Article 4

No consideration of adverse impacts of investment decisions on sustainability factors

Strix does not currently consider the adverse impact of investment decisions on sustainability factors in the manner prescribed by Article 4 of SFDR. Article 4 (b) of SFDR requires investment managers to provide clear reasons why they do not consider the adverse impacts of investment decisions on sustainability factors.

Strix is supportive of the policy aims of the principal adverse impacts(“PAI”)  regime, to improve transparency to clients, investors and the market, as to how financial market participants and financial advisors integrate consideration of the adverse impacts of investment decisions on sustainability factors.

However, taking account of the size, nature and scale of Strix’s activities, Strix considers that it would be disproportionate to consider principal adverse impacts as set out in the PAI regime of the SFDR.

Strix will keep its decision not to consider the adverse impacts of its investment decisions on sustainability factors under regular review.

Article 5

Remuneration Policy Disclosure

Article 5 of SFDR requires financial market participants to include in its remuneration policy information on how those policies are consistent with the integration of Sustainability Risks, (“SFDR Requirements”).

The objective of Strix’s remuneration framework is to establish and maintain an approach to remuneration which is consistent with and promotes sound and effective risk management and does not encourage risk-taking that exceeds the level of tolerated risk of Strix.

Strix aims to achieve a proper balance of variable and fixed remuneration and aims to align its remuneration policy with its long-term interests and to ensure that the clients’ interests are not impaired by the remuneration policies and practices adopted by Strix.

A number of factors will be taken into account by Strix in deciding the quantum of the variable remuneration in any given period. This may include the extent to which an individual has adhered to any approach/policies put in place by Strix relating to the integration of Sustainability Risks.