Environmental, Social and Governance Disclosures

Curmi & Partners Limited (the Company) falls within the scope of the Regulation (EU) 2019/2088 (SFDR) of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (SFDR) as both a Financial Market Participant and a Financial Advisor.

No consideration of sustainability adverse impacts

The Company does not formally consider the adverse impacts of investment decisions on sustainability factors and the Company does not currently intend to consider adverse impacts for its investment strategies as it is not required to do so under the SFDR Article 4.

At product level, the Portfolio Manager has elected to exercise its discretion under Article 4(1)(b) of SFDR not to commit to considering the adverse impacts of investment decisions of the financial products on sustainability factors in the manner specifically contemplated by Article 4(1)(a) of the SFDR but will continue to consider and manage these impacts in line with its Environmental, Social, and Governance Policy.

However, information on ESG Factors and related ESG Risks is incorporated into the Company’s investment decision-making processes and investment advisory process. The Company has established the following ESG related parameters within its investment decision-making process:

• Exclusions – The Company will not invest in entities which operate) within the following industries:
  1. Adult entertainment/Pornography; 
  2. Child labour.

• Conditional exclusion – The Company will not invest in entities which have significant operations (business activity accounts to c.20% of EBITDA) within the following industries:
  1. Tobacco; 
  2. The manufacturing and/or distribution of military weapons.

• The proposed investment portfolio should have an ESG score, as derived from ESG research and data platform MSCI ESG Manager, that is BBB or higher. 
• The portfolio cannot have more than 10% of its investments which are classified as laggards and are therefore, behind in the ESG implementation process.
• The portfolio cannot have more than 30% of its investments which are classified as not covered by the MCSI ESG Manager and therefore, cannot be assessed from an ESG perspective.

The Company does not offer green products or model portfolios, however the Company takes the above ESG related parameters into consideration as part of the asset selection process together with other quantitative and qualitative considerations.

Alignment of Remuneration Policy with Sustainable Investments

In accordance with our Remuneration Policy, the total amount of renumeration is based on a combination of the assessment of the performance of the individual and of the business unit concerned and of the overall results of the Company. When assessing individual performance, financial and non-financial criteria are taken into account. The Company believes that there is no
risk of misalignment with the integration of sustainability risks. As such, we believe our
existing structures are sufficient to prevent excessive risk-taking in respect of sustainability
risks, if any.

For more information, please click here to download the Company’s ESG Policy.