The Company integrates sustainability risks into its overall risk management framework in accordance with Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (“SFDR”).

A sustainability risk is defined as an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.

The Company considers sustainability risks at governance and risk management level as part of its internal policies and procedures, including its Risk Management Framework and Product Governance arrangements. The Company assesses whether sustainability risks are relevant to the financial instruments it offers and whether such risks may have a material impact on their expected returns.

As the Company does not offer financial instruments that pursue sustainable investment objectives or promote environmental, social or governance characteristics, sustainability risks are not currently integrated as a defining feature of the Company’s product offering.

The Company does not currently offer financial instruments that qualify as sustainable investments or that promote environmental, social or governance (ESG) characteristics within the meaning of SFDR.

Accordingly, clients who seek to make sustainable or ESG-focused investments fall outside the Company’s identified target market, as defined in the Company’s Product Governance arrangements.

In accordance with Article 5 of SFDR, the Company ensures that its remuneration policies and practices are consistent with the integration of sustainability risks into its overall risk management framework.

The Company’s remuneration arrangements are designed so as not to encourage excessive sustainability risk-taking. Where applicable, performance assessments take into account compliance with internal policies, risk management requirements and sustainability risk considerations.

The Company further ensures that its remuneration practices do not incentivise the misrepresentation or disregard of sustainability-related risks in the provision of its services.

As the Company does not promote or distribute financial instruments with sustainable investment objectives or ESG characteristics, sustainability risks are considered at governance level and do not currently constitute a performance driver for individual remuneration.