Regulatory Notice

Under the Sustainable Finance Disclosure Regulation, we must inform you whether, in formulating our Investment Advice and Insurance-Based Investment Advice, we consider the principal adverse impacts of investment decisions on sustainability factors. As yet, we do not in general incorporate such consideration. This is because we believe that the relevant disclosures from most funds and investment products do not provide sufficient detail and clarity to support the level of analysis that we would wish to carry out. Moreover, even where comprehensive disclosures are made, the connection between the data and its real-world impact on the relevant factors may be quite unclear. However, in the case of any particular investment, if clear evidence of sustainability risks and/or adverse impacts presents itself in the course of our analysis that will be taken into account in formulating our recommendation.

This position is kept under review and we will commence systematic consideration of principal adverse sustainability impacts if and when the quality of relevant information and the interpretation of same supports an appropriately rigorous analysis.

Notwithstanding the above, when providing investment advice to a Client, we are obliged to enquire as to the Client’s sustainability preferences. If the client expresses particular preferences, we will endeavour to take account of those in formulating a recommendation that is deemed suitable. If we cannot find an investment that satisfies those preferences, the Client will be invited to adapt them. After this stage, if an investment that satisfies either the original or adapted preferences cannot be found, we may make a recommendation with the stipulation that it is non-suitable with respect to sustainability preferences.