Sustainability-related disclosure (SFDR)

Integration of sustainability risks at IWC IP

Sustainability risks are integrated in the investment decision making process and investment advice. The integration is guaranteed by the presence of the following IWC’s Group policies: ESG Policy, SRI Guidelines, Forest Certification Policy, Code of Conduct, and Climate Policy, Investees’ Monitoring & Engagement Procedure.

No consideration of sustainability adverse impacts

IWC IP seeks to carry out all investments in a manner that is socially responsible and environmentally sound, based on a rigorous ESG framework, integrated throughout an investment lifecycle (due diligence, investment decision, holding and exit). While IWC IP is integrating a comprehensive set of sustainability risk indicators in our due diligence, investment selection and advice processes, including many of the indicators listed in Tables 1, 2, and 3 of Annex I of the draft Regulatory Technical Standards, supplementing Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR), we are not yet integrating all the principal adverse sustainability impacts as listed in the aforementioned tables.

However, although we are exempt from the mandatory integration of the principal adverse impacts of investment decisions on sustainability factors (SFDR, Art.4, (3)-(4)), we think those are important and the market will eventually synchronize around their integration. Moreover, the integration and reporting of principal adverse impact indicators is now a prerequisite to sustainable investment objectives. Therefore, we are in the process of reviewing and revising relevant internal policies and procedures, in order to implement the full scope of indicators listed in Table 1 of Annex I and selected indicators listed in Tables 2 and 3 of the same Annex I (C(2022)1931), in our due diligence, investment selection, investment management, and investment advice processes. A process we envision finalizing by the end of 2023, thus start considering the principal adverse impacts of investment decisions/advices on sustainability factors listed in the SFDR’s Commission Delegated Regulation (C(2022)1931), Annex I, Table 1 and selected indicators of Tables 2 and 3, latest in 2024. And thus, start publishing the resulting summary of policies and indicators performance in 2024 and 2025, respectively, per the SFDR’s requirements.

Remuneration Policy and the integration of sustainability risks

IWC Investment Partners A/S’ (IWC IP) does not encourage or reward an excessive assumption of sustainability risks according to its Remuneration Policy. Said policy is therefore consistent with the integration of sustainability risks.