ESG disclaimer

Manentia Wealth Consulting Group (“MWC” or the “Company”) qualifies as a Financial Market Participant in terms of the Sustainable Finance Disclosure Regulation (“SFDR”). As a result, the Company is required to have in place policies and procedures setting out the approach adopted by the Company on the integration of sustainability factors in the investment decision‐making process and within its risk management framework. SFDR defines “sustainability factors” as “Environmental, Social and Governance matters, respect for human rights, anti‐ corruption and anti‐bribery matters” (the “ESG Factors”).

The Company’s investment approach is to provide investment advice towards products which provide long-term benefits and limits investment advice in relation to products which have negative impacts on ESG, the Company feels that these factors are not the primary determinants in the provision of investment or insurance advice.

We believe that the weight of ESG factors when providing investment advice depends largely on other factors such as the investment objective, risk tolerance and time horizon of the investment in relation to the client’s profile.

Negative and positive screening

We will actively engage with our clients to understand whether they have concerns about specific activities and / or industries in order to maintain such exclusions on an on-going basis.

Exclusions

We will not knowingly invest in entities / advise upon investments in entities involved in the following activities:

  • manufacture of tobacco;
  • hard spirits;
  • arms manufacturing;
  • gambling: and
  • genetically modified organisms.

We will assess these types of investments on a case-by-case basis and any potential for indirect exposure is carefully considered and factored into investment selection.

No consideration of sustainability adverse impacts

We do not undertake an assessment of the Principal Adverse Impacts (“PAIs”) of our decisions on ESG Factors. PAIs are those impacts arising from a particular decision taken / investment recommendation made that will eventually have a negative effect on ESG Factors.

Currently, there is no universally accepted framework or list of factors to consider to ensure that investments are sustainable which means that there is a lot of subjectivity and uncertainty when it comes to the accuracy and comparability of data. It is important to note that the legal and regulatory framework governing sustainable finance is still under development.

Should the approach to the consideration of sustainability factors and the related risks change, either following finalisation of the regulatory and legal framework, or based on decisions by the Company with regard to the investment policies of its clients then this Policy will be updated.

Alignment of Remuneration Policy with sustainability investments

In line with our Remuneration Policy, no variable remuneration is paid to our staff unless it is determined to be justified following a performance assessment based on quantitative (financial) as well as qualitative (non-financial) criteria.

Due to this very limited impact on the risk-profile of our clients, as well as the nature of our business, we deem that there is no risk of misalignment with the integration of the sustainability risks, if any, in our investment decision making process with respect to our clients / investment recommendations given to our clients.

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