As a “financial market participant” and “financial advisor”, Banor SIM makes decisions on portfolio management and investment advisory services taking into account sustainability risk. This refers to the risk that the value of an investment may be adversely impacted by events or conditions of an environmental, social or governance nature.
ESG factors are integrated into investment decisions by identifying exclusion criteria (negative screening), analysing and monitoring ESG risks in the portfolio and monitoring ongoing disputes with issuers.
However, as of the date of this statement, and despite having already undertaken an internal process aimed at integrating risk and sustainability factors into its decision-making processes, the Company declares that, in this first phase, it does not take into consideration the adverse effects of investment decisions on sustainability factors pursuant to Article 4 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019.
This is because, although the indicators for investments in investee undertakings, sovereign issuers and supranational organisations have been defined in Regulation (EU) No. 2022/1288, the metrics for measuring these indicators are not yet fully developed and the relevant data is sometimes not available, so the Company has not implemented specific procedures to collect it.
When complete and consistent information for measuring indicators becomes available, the Company will consider taking into account the adverse effects of investment decisions and investment advice on sustainability factors pursuant to Article 4 of Regulation (EU) 2019/2088.