Sustainability disclosures

STATEMENT BY "DV ASSET MANAGEMENT" EAD THAT THE ENTITY DOES NOT CONSIDER ADVERSE IMPACTS OF ITS INVESTMENTS DECISIONS AND INVESTMENT ADVICE ON SUSTAINABILITY FACTORS

Currently „DV Asset Management“ EAD does not consider adverse impacts of its investments decisions and investment advice on sustainability factors, regarding both the management of the mutual funds that it represents and governs (MF)  and the portfolios of clients with whom  contracts for confidential governance of portfolio of financial instruments have been concluded, as well as in the process of providing investment advice (consultations).

The reasons for not considering adverse impacts are:

  • the specifics of the imperative provisions of the sectoral legislation at the national and supranational level - when providing services, the company should act in the best interest, considering the risk profile and investment policy of both its clients in confidential governance and in relation to the MF, as well as in the provision of investment advice (consultations);
  • The company commits all its available resources to achieve the goals of its clients, which currently do not include requirements for sustainable investments;
  • the absence of reliable and free-for-all available methods for disclosing information from public companies regarding the presence or absence of ESG data, which could possibly provide an opportunity to form objective information about potential adverse impacts;
  • considerations of whether a sufficient volume of information/data can be provided regularly by all public companies in a comparable digital format;
  • the lack of guarantees/control in relation to the publication of misleading information, the risk of allowing the so-called "greenwashing" or other types of misinformation, etc.;
  • the scale of the Company's activities and the portfolios managed by it - size, nature and scope of the activities, as well as the type of financial services provided, relative to the potential costs of technical and software provision, human resources, etc., which would guarantee timely and correct disclosure of potential adverse effects;
  • the time required to implement a software solution, hire additional staff, and provide access to financial resources;
  • the ongoing procedure for the development of a single European legal framework in relation to the disclosure of information on sustainability risks for financial market participants.

Although at this stage „DV Asset Management“ EAD does not consider adverse impacts of its investments decisions and investment advice on sustainability factors, the company  performs an ongoing review of the regulatory framework and customer preferences, and when the reasons for non-reporting no longer exist and after taking into account the future benefits and costs associated with possible reporting of adverse impacts, it will endeavor to start reporting these impacts in compliance with the principle of action in the best interest of its clients.