ESG

§ 7

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1. At the current stage, the Company does not have a strategy for introducing sustainable development risks into its operations in the process of making investment decisions, as referred to in Art. 3 section 1 of the SFDR Regulation.

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2. The company may invest its assets in investments promoting environmental and/or social aspects, but it does not have sustainable investments as a goal (light green investments).

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3. Sustainability risk should be understood as an environmental, social or management situation or conditions which, if they occur, could have an actual or potential significant negative impact on the value of investments made by the Company.

 

4. Factors influencing the level of risk for sustainable development include in particular:

a. climate change caused by global warming;

b. compliance with the principles of rational use of water and sea resources; 

c. compliance with generally recognized labor standards (e.g. prohibition of child labor, forced labor or discrimination in the workplace);

d. respecting the rights of trade unions and the right of employees to associate;

e. guarantee of the safety of the offered products and their impact on health;

f. organizational sensitivity of enterprises to the good of the local community and minorities;

g. compliance with the principles of tax honesty;

h. compliance with the principles of personal data protection.

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5. Principles of taking into account sustainable development risks in the Company's activities in the process of making investment decisions:

a. the basis of the Company's investment process is a multidimensional analysis of entities, which, in addition to financial aspects, also takes into account numerous factors related to the nature of the business;

b. the shelf recognizes the impact of sustainable development factors on risk factors characteristic of investment products (including market risk, liquidity risk);

c. The Company recognizes sustainability risks as factors of defined risk types that may influence them and contribute to increasing their significance;

d. if it results from an individual assessment, sustainable development risks may not be taken into account in the investment decision-making process.

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6. As regulations on the disclosure of information related to sustainable development develop, as industry standards are developed for taking into account sustainability risks in the investment decision-making process, and as the availability of sustainability data from third-party sources increases, ESG provisions may change , aimed at adapting them to current market practices/standards.

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7. When making investment decisions, the unfavorable effects of investment decisions on sustainable development factors are not taken into account, which is caused by the limited availability of data necessary to conduct a proper analysis of entities in the above scope. As the quality and availability of data reported by entities improves, the Company will consider applying these requirements in the future.