Разкриване на информация във връзка с устойчивостта

  • 03.07.2022
Disclosure of information on sustainabilityDisclosure of information on sustainability

Disclosure of information on sustainabilityDisclosure of information on sustainability

Disclosure of information on sustainability

The transition to a sustainable, low-carbon, resource-efficient circular economy is key to the long-term competitiveness of our economy. The sustainability or environmental, social and managerial nature of investment is becoming an increasingly important factor in this transition. Criteria of an environmental, social and managerial nature address issues such as climate change, air and water pollution, biodiversity, human rights, social standards, corporate governance and many more. These criteria help to better determine the future financial results of companies (return and risk).

Axiom Invest Ltd. strongly supports all measures aimed at environmental protection, protection of employees' rights and better corporate governance, which are generally defined as sustainability factors. In this regard, the company took note of the requirements of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of information regarding sustainability in the financial services sector (Sustainable Finance Disclosure Regulation or SFDR) and and Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 establishing a framework to facilitate sustainable investment and amending Regulation (EU) 2019/2088 (Regulation (EU) 2020/852) and related European regulations.

Nachman Capital Ltd. at the time of adoption of its Policy for the integration of risks to sustainability in its investment decision-making process in portfolio management and investment advice and to take into account the adverse effects of investment decisions on sustainability factors, does not provide portfolio management services providing investment advice, regardless of the fact that they are included in the license issued to the company. Също така дружеството не създава и не дистрибутира паневропейски пенсионни продукти.

Notwithstanding the above and pursuant to Article 4 (5.b) of the SFDR, at this stage Nachman Capital Ltd. has chosen not to take into account in its investment advice and portfolio management adverse effects of investment decisions on sustainability factors for the following reasons :

1. The legal framework, both at European and national level, is incomplete.

  • The regulatory technical standards that are expected to be adopted under the SFDR are still at the draft stage.
  • The existing regulation is scattered between different European acts, which were adopted at different times and which are not fully coordinated with each other.
  • A change in MiFID II is forthcoming.
  • The normative acts that will introduce measures for the implementation of the European regulations in the domestic legislation have not been adopted yet.

2. Lack of information from issuers.

  • Currently, only some large issuers are required to disclose non-financial information relevant to sustainability factors, and the information they disclose is not detailed enough.
  • EU rules on non-financial disclosure do not apply to third country issuers.
  • The company must have a secure and reliable data source in order to be able to take into account the factors of sustainability in providing investment advice and portfolio management.

3. Taking into account the adverse effects on sustainability requires review and revision of many of the internal rules and policies of the Company, which will take a lot of time and effort, especially given that the legal framework is not complete.

  • The Project implements the Remuneration Policy, which aims to establish clear and objective principles of remuneration of certain categories of staff and ensure reliable and effective risk management and non-promotion of risk-taking that exceeds acceptable levels for the investment intermediary. The integration of sustainability risks in the investment decision-making process in client portfolio management and in providing investment advice to clients will not adversely affect the sound and effective risk management and non-encouragement of risk-taking by the investment firm.
  • In order to decide to take into account sustainability factors, the Project will review and revise all its internal rules and policies, and adopt the necessary changes, especially in the risk management rules and remuneration policy.
  • At present, the scale of the Company's activities, as well as the nature and scope of its activities, especially those related to portfolio management and investment advice, do not justify the adoption of additional administrative measures and costs.