Declaration on the main adverse impacts of investment decisions on sustainability factors

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 results of the companies (return and risk).

"Axiom Invest" Ltd. strongly supports all measures aimed at protecting the environment, protecting the rights of employees and better corporate governance, which are generally defined as sustainability factors. In this regard, the company has familiarized itself with the requirements of Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 regarding the disclosure of information related to 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 June 18, 2020. to create a framework to facilitate sustainable investment and to amend Regulation (EU) 2019/2088 (Regulation (EU) 2020/852) and related European regulation.

  "Axom Invest" Ltd. at the time of adoption of its Policy on the integration of sustainability risks in its investment decision-making process for portfolio management and investment advice and for considering the adverse impact of investment decisions on sustainability factors, does not provide portfolio management services, provision of investment advice, regardless of the fact that the same are included in the license issued to the company. Also, the company does not create or distribute pan-European pension products. Notwithstanding the above and on the basis of Article 4, Paragraph 5.b of the SFDR, at this stage Axiom Invest Ltd. has chosen not to consider in its investment advice and portfolio management the adverse impacts of investment decisions on sustainability factors.

Regulation (EU) 2019/2088 and Regulation (EU) 2020/852 introduce obligations for investment intermediaries that provide the following services:

- Portfolio management and making investment decisions in this regard;

- Provision of investment advice;

- Creation and/or distribution of a pan-European pension product.

Axiom Invest Ltd. does not provide services for active portfolio management, provision of investment advice and creation and/or distribution of a pan-European pension product, therefore, at the moment, introduced by Regulation (EU) 2019/2088 and Regulation (EU) 2020/ 852 requirements are not relevant and applicable to the company's activities. When starting an activity to provide services falling within the scope of Regulation (EU) 2019/2088 and Regulation (EU) 2020/852, Axiom Invest Ltd. will take all necessary actions to update the internal regulations in the investment intermediary and comply with the activity with the introduced regulatory requirements in the field of integrating sustainability risks and accounting for adverse impacts on sustainability.

  The Broker Dealer implements a Policy on the formation of remuneration, which aims to establish clear and objective principles of remuneration of certain categories of staff and ensure reliable and effective risk management and not encourage the assumption of risk that exceeds acceptable levels for the investment intermediary. Integrating sustainability risks into the investment decision-making process when managing client portfolios and when providing investment advice to clients will not adversely affect the reliable and effective management of risks and disincentive risk-taking by the investment intermediary. In order to decide to consider sustainability factors, the Broker Dealer will review and revise all its internal rules and policies, and adopt the necessary changes, especially in the risk management rules and in the remuneration policy.

Currently, the scale of the Company's activities, as well as the nature and scope of its activities, especially related to portfolio management and investment advice, do not justify the undertaking of additional administrative measures and costs.