Declaration of Non-Examination of the Adverse Effects of Investment Decisions on Sustainability Factors 10/02/2022

The company informs the investing public that it has established and implements a policy on the integration of sustainability risks* in the process of making investment decisions and providing investment advice in accordance with the provisions of Regulation (EU) 2019/2088, which you can read by clicking on the following link of Sustainability and Responsible Investment Policy January 26th, 2022

However, the Company states that:

1. or the moment it does not take into account the adverse effects of investment decisions on sustainability factors*, for the reason that no data is yet available regarding these factors for all the issuers of financial instruments included in the pooled (UCITS and AIFs) and the individual portfolios it manages, as well as those it recommends to its clients when providing investment advice and
2. as soon as the above data on sustainability factors become available, the Company intends to modify its above policy, adopting a specific procedure, in order to take into account the main adverse effects of investment decisions on sustainability factors.

* "sustainability risk": an event or circumstance in the environmental, social or governance factor which, if it occurs, could have an actual or potential material adverse effect on the value of an investment.

* "sustainability factors": environmental and social issues, personnel issues, respect for human rights and the fight against corruption and bribery.