Sustainability disclosure under Regulation (EU) 2019/2088
The transition to a sustainable, low-carbon, resource-efficient circular economy is key to the long-term competitiveness of our economy. Sustainability, or the environmental, social and governance nature of investments, is becoming an increasingly important factor in this transition. Environmental, social and governance criteria address issues such as climate change, air and water pollution, biodiversity, human rights, social standards, corporate governance and many others. These criteria help to better determine the future financial performance of companies (return and risk).
Axiom Invest Ltd. strongly supports all measures aimed at environmental protection, the protection of employee rights and better corporate governance, which are generally defined as sustainability factors. In this regard, the company has become familiar with the requirements of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of information in relation to sustainability in the financial services sector ( Sustainable Finance Disclosure Regulation or SFDR ) and the related European regulation.
It should be borne in mind that the license held by the Investment Firm includes the provision of investment services and activities under Art. 6, para. 2, item 4 and item 5 of the Markets in Financial Instruments Act (MFIA), namely "portfolio management" and "investment advice", but in practice The Investment Firm does not provide these services to professional and non-professional clients, respectively to professional and non-professional investors within the meaning of Article 2, paragraph 1, point 18 and point 19 of Regulation (EU) 2019/2088.
At present, the Investment Intermediary does not plan to start offering the investment services and activities of "portfolio management" and "investment advice" to the intermediary's clients (professional and non-professional investors).
Given the fact that the company does not currently offer portfolio management services and/or investment advice, pursuant to Article 4, paragraph 5.b of the SFDR, the II:
➔ currently does not take into account the adverse impacts of investment decisions on sustainability factors, as the investment intermediary does not make investment decisions because it does not provide portfolio management to professional and non-professional investors.
➔ currently does not take into account the adverse impacts of investment decisions on sustainability factors in its investment advice, as the investment intermediary does not provide investment advice to professional and non-professional investors.
➔ does not currently perform pre-contractual disclosure of information about financial products it provides, as it does not provide portfolio management to professional and non-professional investors and therefore does not provide the financial product - portfolio managed in accordance with Article 4, paragraph 1, point 8 of Directive 2014/65/EU.
➔ The Investment Firm also does not provide any other financial products within the meaning of Article 2, paragraph 1, point 12 of Regulation (EU) 2019/2088.
➔ does not currently perform pre-contractual disclosure of information about financial products for which it provides advice, as it does not provide investment advice to professional and non-professional investors.
➔ The Investment Firm applies a Remuneration Policy, which aims to establish clear and objective principles for the remuneration of certain categories of staff and to ensure sound and effective risk management and discourage risk-taking that exceeds the levels acceptable to the investment firm. in a clear and accessible manner. In relation to Art. 5, paragraph 1 of Regulation (EU) 2019/2088 regarding the transparency of the remuneration policy in relation to the integration of sustainability risks, the Investment Firm has not currently included in its remuneration policy information on how this policy is aligned with the integration of sustainability risks, as the Investment Firm does not take sustainability risks into account as it does not provide investment advice and portfolio management to professional and retail investors.
➔ currently does not take into account the adverse impacts of investment decisions on sustainability factors, as the II does not make investment decisions because it does not provide portfolio management to professional and non-professional investors.
➔ does not currently perform pre-contractual disclosure of information about financial products it provides, as it does not provide portfolio management to professional and non-professional investors and therefore does not provide the financial product - portfolio managed in accordance with Article 4, paragraph 1, point 8 of Directive 2014/65/EU.
➔ At present, the Investment Firm does not make the declaration under Article 7, paragraph 2 of Regulation (EU) 2019/2088, since for the reasons stated above it does not disclose information under Article 6, paragraph 3 of Regulation (EU) 2019/2088.
➔ At present, the Investment Firm does not disclose information under Art. 8, Art. 9, Art. 10 and Art. 11 of Regulation (EU) 2019/2088, as for the reasons stated above, it does not disclose information under Article 6, paragraph 3 of Regulation (EU) 2019/2088.
➔ Currently, the II has not integrated sustainability risks into its investment decisions and investment advice, as it does not provide investment advice and portfolio management to professional and non-professional investors.
If and when the Investment Firm decides to start providing portfolio management to professional and retail investors, then the Investment Firm:
➔ will start to take into account the adverse impacts of investment decisions on sustainability factors and will make the relevant disclosure in accordance with Article 4, paragraph 1, letter "b" of Regulation (EU) 2019/2088.
➔ will start to take into account the adverse impacts of investment decisions on sustainability factors and will make the relevant disclosure in accordance with Article 4, paragraph 5, letter "b" of Regulation (EU) 2019/2088.
➔ will include in its remuneration policy information on how this policy is aligned with the integration of sustainability risks and will make the relevant disclosure in accordance with Article 5(1) of Regulation (EU) 2019/2088.
➔ will provide the financial product - a portfolio managed in accordance with Article 4, paragraph 1, point 8 of Directive 2014/65/EU, therefore it will carry out pre-contractual disclosure of information, which will include the information under Article 6, paragraph 1 and paragraph 3 of Regulation (EU) 2019/2088
➔ will carry out pre-contractual disclosure of information, which will include the information under Article 6, paragraph 2 of Regulation (EU) 2019/2088
➔ will carry out pre-contractual disclosure of information, which will include the information under Art. 6, paragraph 1 and paragraph 3 of Regulation (EU) 2019/2088, as well as the information under Art. 7, paragraph 2, Art. 8, Art. 9, Art. 10 and Art. 11 of Regulation (EU) 2019/2088.
➔ will integrate sustainability risks into its investment decisions and investment advice.
Publication date: 30.12.2021.
Date of last review/update: 12.05.2025.
