Resilience factors

Expat Asset Management EAD has adopted and complies with the Policy for the Integration of Sustainability Risks into Investment Decision Making Processes, which is applied both to the management of the portfolios of the undertakings for collective investment in securities managed by the company and to the management of the individual portfolios of the company's clients. The policy can be found in the Documents section.

Although it applies the policy described above, Expat Asset Management EAD does not take into account the adverse impacts of investment decisions on sustainability factors within the Article 4(1)(b) of Regulation (EU) 2019/2088 - both in the management of the portfolios of the undertakings for collective investment in securities managed by the firm and in the management of the individual portfolios of the firm's clients, and in the case of the provision of investment advice on financial instruments. The reasons for this are as follows:

• At this stage, considering the adverse impacts of investment decisions on sustainability factors will limit the opportunities for achieving better returns and diversification for trust clients and for investors in actively managed collective investment schemes.
• The Firm provides its fiduciary clients with the ability to place investment restrictions on the management of their portfolios, including those related to prioritizing sustainability risks. It is important to note, however, that to date no client has taken advantage of this option and has not indicated a desire to do so.
• Taking into account the adverse impacts of investment decisions on sustainability factors according to the Article 4 of Regulation (EU) 2019/2088 will result in a significant expenditure of resources (human, managerial and financial) for the firm without resulting in any expected and measurable increase in earnings in the medium or even long term. Management's priority is to ensure the Company's financial stability, capital adequacy and operating profitably. As such, considering the adverse impacts of investment decisions on sustainability factors is not compatible with these objectives at this stage.
• At this stage, the Company has not identified any tangible demand from investors who prioritize considering the adverse impacts of investment decisions on sustainability factors over good risk diversification and investment returns. If, in the future, it identifies tangible demand from investors for whom consideration of the adverse impacts of investment decisions on sustainability factors is a priority and overrides good diversification of risk and return on investment, the Company will take action to consider the adverse impacts of investment decisions on sustainability factors.