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No Consideration of Sustainability Adverse Impacts

Regulation (EU) 2019/2088- Sustainable Finance Disclosure Regulation (“SFDR”) requires financial market participants to disclose whether or not they consider sustainability factors in their investment decision making and advisory processes . Sustainability factors encompass (i) environmental and the climate; (ii) social and employee matters; (iii) respect for human rights; (iv) anti-corruption; and (v) anti-bribery matters. To effectively assess what the principle adverse sustainability impacts are for a business and/or fund it must first identify any sustainability risks that may exist. SFDR defines sustainability risks as being an environmental, social or governance event or condition that, if occurs, could cause an actual or a potential material negative impact on the value of the investment.

As a result, SFDR expects those financial market participants who take principal adverse sustainability impacts into account to publish a statement in accordance its requirements. That statement must disclose how the financial market participant intends to deal with minimizing adverse impacts and how adverse impacts is considered by it in its investment decision-making process.

Equity Trustees Fund Services (Ireland) Limited (“ETFSI”) is the appointed management company to a number of investment funds (“Funds”). The majority of the Funds for which we are responsible are currently within the scope of Article 6 of SFDR as they have do not currently have objectives and policies that require an inclusion of ESG factors in the investment process. Certain Funds, for which ETFSI acts as Manager, are within the scope of Article 8 of SFDR and in doing so they consider some principal adverse impacts in determining appropriate investments for the Fund(s).  As Article 8 Funds, not all principal adverse impacts are required to be assessed under SFDR are included and prospective investors should make enquiries with the appointed Fund sub-investment manager or distributor to ascertain which impacts are not considered or for further information on their approach to SFDR.

For those Funds where ETFSI retains the investment management role the “No Consideration of Sustainability Adverse Impact Statement” applies as it is not currently embedded in the investment process.

ETFSI continuously monitors the SFDR requirements and reserves the right to update, amend, alter or retract any aspect of this Statement.  ETFSI supports and encourages its delegates to include ESG factors in their investment process where appropriate.

UCIT Platform
SFDR Article
Sub-Investment Manager
The Gateway UCITS Funds p/c
Ecofin Energy Transition UCITS Fund 8 Ecofin Advisors Limited
  The Written Fund (a Covered Option Writing Fund) 6 Gate Capital Group Limited
Evenlode ICAV
Evenlode Global Dividend Fund
6 Evenlode Investment
  Evenlode Global Opportunities Fund  Evenlode Investment
TC New Horizon ICAV
TC New Horizon Global Balanced Fund
6 Equity Trustees Fund Services (Ireland) Limited
Global Impact Initiative UCITS ICAV GII Global Gender Equality Fund 8  RobeccoSAM AG