Sustainability

INFORMATION PROVIDED BY RECORDE ASSET MANAGEMENT LTD (1123 BUDAPEST, ALKOTÁS UTCA 55-61. – “FUND MANAGER”) ACCORDING TO ARTICLE 3 (1), 4 AND 5 OF REGULATION (EU) 2019/2088 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (SFDR):

Considering sustainability factors (i.e. environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters) in investment projects can have a significant positive impact on the value of investments. Sustainability risks, on the other hand, may negatively affect investments. A sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential negative material impact on the value of the investment. These include activities that significantly harm the environment, fundamental human rights violations, the use of child labour, serious violations of workers’ rights and discrimination in the workplace.

Regulation

Regulation (EU) 2019/2088 of the European Parliament and of the Council (SFDR), which is directly applicable in all EU Member States, including Hungary, provides that management companies shall publish information on sustainability:

(1) they shall publish information about their policies on the integration of sustainability risks into their investment decision‐making process (Article 3);

(2) where they consider principal adverse impacts of investment decisions on sustainability factors, they shall also publish a statement on due diligence policies with respect to those impacts, taking due account of their size, the nature and scale of their activities and the types of financial products they make available (Article 4); and

(3) with respect to investment funds they manage, they shall provide information on sustainability in their prospectuses and management policies (Article (6)).

Recorde Asset Management Ltd’s sustainability policy for investment decisions

As a financial market participant subject to SFDR, Recorde Asset Management Ltd recognises that sustainable development is a key issue and that sustainability risks must be proportionally integrated into investment decision-making processes, taking due account of the company’s size, the nature of its activities and the types of investment funds it manages as financial products under SFDR. This means Recorde is committed to implementing this approach into its operations, corporate governance and activities and taking into account relevant, internationally accepted standards.

 

Information on investment funds managed by Recorde

The Fund Manager declares that for all the investment funds under its management, the investments underlying the relevant financial products do not take into account the EU criteria for environmentally sustainable economic activities. The way in which sustainability risks are incorporated into its investment decision-making processes is set out in point 65 (Additional information on the investment fund) of its prospectus. The prospectuses are available at the Company's registered office. Articles 8 and 9 of the SFDR do not apply to the Investment Funds of the Manager.  

The integration of sustainability risks into remuneration practices

One of Recorde’s core objectives is to follow remuneration practices that allow for prudent risk management and do not encourage taking risks – including sustainability risks – that are not in line with its investment decision-making and responsible corporate governance procedures.

  Budapest, 8 July 2024   Recorde Asset Management Ltd.