SFDR Disclosures
This disclosure is being published in accordance with Regulation (EU) 2019/2088 (SFDR) of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the investments services sector, which came into effect on 10th March 2021. Finco Treasury Management Limited (FTM) falls within scope both as a Financial Market Participant and as a Financial Advisor.
Transparency of Sustainability Risk Policies
SFDR aims to increase transparency regarding how sustainability risks are integrated into investment decisions and investment advice by Financial Market Participants and Investment Advisors.
FTM implements processes that consider Environmental, Social and Governance (ESG) risk factors as part of a group of considerations that make up an investment decision-making processes.
Transparency of Adverse Sustainability Impacts at Entity Level
Along with the investment objectives, investment time horizon, and the client’s risk attitude, ESG Factors will also be included in the overall investment selection process. However, these ESG factors will not be considered as the primary deciding factor. This approach does not automatically exclude an investment on ESG grounds.
FTM does not undertake an assessment of the Principal Adverse Impacts (PAIs) of its decisions on ESG Factors. Still, it will consider investments that are environmentally and socially responsible as much as possible.
FTM engages with clients to understand whether they have concerns about specific activities and/or industries and/or issuers of securities to maintain exclusions on an ongoing basis. In such cases, FTM will screen target investment houses and/or products consistent with the clients’ sustainability preferences and aim to recommend and/or invest in accordance with such client preferences on an ongoing basis.
FTM also aims to steer away from any investments which may be significantly in conflict with what the Company considers to be socially and/or environmentally responsible investment decisions or advice.
PAIs are determined with reference to specific Adverse Sustainability Indicators and on the basis of complex metrics for investee companies, sovereign and supranational bonds. FTM, in its investment advice and investment decisions, offers a diverse range of financial instruments that would make such determination difficult in the absence of reliable and available data that is capable of being determined across such instruments. FTM shall continue to monitor the transparency and availability of ESG data and ratings and may accordingly reconsider its decision to consider principal adverse impacts in the future.
Alignment of Renumeration Policies with Sustainability Investments
The Regulation requires Financial Market Participants and Financial Advisors to evaluate how to account for their ESG risks in their remuneration policies. In aligning the remuneration policy with ESG objectives, it is important to avoid conflicts of interest when business decisions are taken, including in particular in the determination of the staff remuneration policies. FTM has always adhered to a policy of awarding salaries that are not dependent on the volume, value or type of products sold. FTM has no intention to deviate from this policy which ensures that there is absolutely no incentive to take uncalled for risk-taking, including those in respect of sustainability risks or those issued by any particular issuer.
Last Revised: 21st February 2025
