SFDR Disclosures – No Consideration of Sustainability Adverse Impacts

Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (the “Regulation”), also referred to as the ‘Sustainable Finance Disclosure Regulation (“SFDR”), seeks to achieve more transparency regarding how ‘financial market participants’ and ‘financial advisers’ integrate sustainability risks into their investment decisions and investment advice.

Consequently, this Regulation requires financial market participants and financial advisers to publish written policies on the integration of sustainability risks and to ensure the transparency of such integration. GlobalCapital Financial Management Limited (“GCFM”) falls within the scope of the Regulation and is disclosing here-below the required information in terms of its regulatory requirements.

GCFM’s aim is to consistently take investment decisions or provide investment advice in a highly professional manner and in the best interest of its clients, based on its market knowledge, experience and access to research, and on the basis of a medium or long term investment horizon.

While, at this point in time, in view of its relatively small size and the potentially laborious and cumbersome application of the Regulation, GCFM does not formally and explicitly integrate sustainability risks and consider the adverse impacts (Principal Adverse Impact – “PIA”) of its investment decisions on sustainability factors as indicated by Article 4 of the Regulation (EU) 2019/2088, it shall nonetheless continue to consider, as part of its overall considerations prior to any investment decisions or advice, any significant environmental, social or governance implications connected to a proposed investment that are known to it or that it may become aware of and that may be considered to impact the long-term financial performance of that proposed investment.

GCFM also aims to move away from any investments which may be in any way significantly in conflict with what the Company would consider to be socially and/or environmentally responsible investment decisions or advice. GCFM will continue to monitor market conditions and regulatory developments and may at a later stage consider the application of the provisions of this Regulation.


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