Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on the disclosure of information related to sustainability in the financial services sector (hereinafter, the “Disclosure Regulation”) requires that Austral Venture Management, SGEIC, S.A.U. (hereinafter, “the Entity”) make certain disclosures on its website, including information on the SGEIC’s policies on the integration of sustainability risks in its investment decision-making process; its focus on the adverse impacts of sustainability; and the coherence of its remuneration policies with the integration of sustainability risks. Its objective is that end investors can have information on the integration of sustainability risks carried out by entities. In this regard, note that as part of the evaluation of investments, the SGEIC, through its advisory team, will consider, if it deems appropriate, the relevant risks to the sustainability of potential investments.
The Entity tries to adequately recognise, evaluate and weigh all relevant risk factors when preparing investment recommendations for its clients. Thus, sustainability risks are only one of several aspects of risk considered as part of investment decision making. Other risk factors considered could be (although not exclusively): market, liquidity and/or counterparty risks. Therefore, ESG (environmental, social and governance) factors and risks are taken into account in the investment decision-making process as an additional tool that offers greater information on current and potential non-financial risks of investments. Therefore, it must be understood jointly with the traditional and not exclusive analysis of “sustainable investment”.
Although the SGEIC believes that sustainability risks could have a positive or negative impact on the returns on customer portfolios, these impacts are not material, given the management model followed within the Entity.
Due to all of the above, the SGEIC currently does not have specific sustainability risk policies, or any other similar type of ESG policies, for its investments.
In accordance with the provisions of article 4 of the Disclosure Regulation, it is reported that currently the Entity does not take into account the adverse effects of investment decisions on sustainability factors (PIAS), due to the fact that it does not currently have information detailed or due diligence policy in relation to such adverse incidents.”
The Entity considers that its remuneration policy is consistent with its approach to integrating sustainability risks into the investment decision-making process.
Sustainability risks are taken into account, among other potentially relevant risk factors, when making investment decisions and failure to take into account any of the relevant risks could have an adverse impact on investment performance.
In general, the Entity’s remuneration policy is based on fixed and variable remunerations. Variable remunerations are determined on a discretionary basis and are strongly linked to the results of each employee and the overall financial results of the Entity. Under this system, any failure to consider sustainability risks with an adverse impact on investment performance would be reflected in the level of global variable remuneration awarded to staff. Furthermore, in this case, adverse performance is likely to have an impact on variable compensation at the individual level.
