SPDR Disclosures for Hamon Asian Funds

2021年03月04日 星期四


SPDR Disclosure

Article 3 - Transparency of sustainability risk policies Hamon Ireland Limited (the “Company”) is the management company to a unit trust, Hamon Asian Funds (the “Unit Trust”), and its two sub-funds. Under Article 3 of Regulation (EU) 2019/2088 (the “SFDR”), financial market participants, such as the Company, must publish information about their policies on the integration of sustainability risks in their investment decision-making process. The Company has appointed Hamon Asset Management Limited to act as Investment Advisor to the Unit Trust. A sustainability risk in the context of the Unit Trust 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. The sustainability risks which may be relevant to the Unit Trust are listed in its prospectus, and are integrated into the Investment Advisor’s investment decisions for the sub-funds, as further detailed in the prospectus. The Investment Advisor [on behalf of the Company] undertakes initial and ongoing assessment of the likely impact(s) of the sustainability risks on the returns of the Sub-Fund. Where the level of risk is deemed to be unacceptable, the Investment Advisor will either not invest or sell the holding. Article 4 – Transparency of adverse sustainability impacts at entity level Article 4(1)(b): The regulatory technical standards supplementing SFDR (the “RTS”) which will set out the content, methodology and information required in the principal adverse sustainability impact statement remain in draft form and have been delayed. The Company intends to consider the principal adverse impacts of investment decisions on sustainability factors once the RTS come into effect, which is expected to occur on 1 January 2022. Article 5 – Transparency of remuneration policies in relation to the integration of sustainability risks Compliance with Regulation (EU) 2019/2088 on Sustainability-related Disclosures in the Financial Services Sector (the “SFDR”) The Company is required to comply with Article 5 of the SFDR, which requires the inclusion in its remuneration policy of information on how there is consistency with the integration of sustainability risks. The recitals provide that the SFDR is without prejudice to the rules on remuneration under the Irish UCITS V Regulations, including but not limited to the relevant applicable proportionality criteria such as the nature, scope and complexity of the activities in question. As set out further above in this policy, the Company has in place remuneration policies and practices, for identified staff, that are consistent with and promote sound and effective risk management and do not encourage risk-taking which is inconsistent with the risk profiles of the Company. In addition to the above, the Non-Executive members of the Board of Directors receive a fixed fee only and do not receive performance-based remuneration, therefore avoiding a potential conflict of interest or an encouragement of excessive risk-taking with respect to sustainability risks.