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Sustainable Finance Disclosure Regulation (SFDR) Policy for Praxis PES Malta Limited

As a ‘financial market participant’ in terms of Regulation (EU) 2019/2088 (also known as the Sustainable Finance Disclosure Regulation or SFDR), we are subject to certain requirements relating to sustainability‐related disclosures in the financial services sector.

We have performed a sustainability risk assessment to firstly determine the relevance of sustainability risks in respect of our business activities, and secondly to disclose the relevance or otherwise of sustainability risks in terms of the said Regulation.

While it is our policy to promote the awareness and integration of environmental, social and governance (ESG) factors, it may not always be appropriate or possible to integrate sustainability risks into our processes and activities.

Furthermore, our remuneration structure is not dependent on variable factors unless this is justified following an internal assessment and is therefore not considered to encourage risk‐taking with respect to sustainability risks and/or linked to risk‐adjusted performance.

Notwithstanding the aforesaid, it remains our policy to perform an ongoing assessment of our products to ensure the suitability thereof for the identified target market.

The products administered by Praxis PES Malta Limited consist of the following:

  1. The APS Occupational Pension Scheme & The APS Personal Pension Plan

The appointed investment manager of the APS schemes integrates sustainability risks in its investment decision-making processes relating to the schemes’ strategies by considering various environmental, social and governance factors.

  1. Member-Directed Schemes

Such schemes offer the possibility to members to appoint their own investment manager or investment advisor, or in certain cases, to manage or direct their own investments. The consideration of principal adverse impacts on sustainability factors therefore depends on the investment policy agreed to individually by each member.

As the scheme administrator, it is our role to review the investment instructions to ensure that the investments are suitable for the pension plan, fit within each member’s risk profile and made within the parameters allowed by law. It is therefore not our remit to reject trades based on whether they consider sustainability factors.

We encourage you to read the relevant pre-contractual document being entered into to determine the extent to which sustainability risks are integrated in the processes adopted for the respective product, and to reach out to us with any concerns about specific activities and/or industries.