Creative Financial

Sustainable Finance Disclosures Regulation

In accordance with the Sustainable Finance Disclosure Regulation (‘SFDR’), we inform you that in our advice about insurance-based investment products (‘IBIPs’) we assess, in addition to relevant financial risks, relevant sustainability risks as far as this information is available in relation to the products advised on. More specifically, this means that we assess environmental, social or governance conditions that, if they occur, could have a materially negative impact on the value of the investment.

We integrate these risks into our advice in the following way:

An obligatory assessment of the clients’ preferences, in relation to environmentally sustainable investing, is conducted by our investment advisors. This is done prior to an investment advisor presenting investment opportunities to the client or potential client.

If clients declare sustainability preferences, then they are asked to describe their preferences in detail by choosing from the following options.

1. Environmentally Sustainable Investments (Also known as ‘Taxonomy-aligned’ investments)

2. Sustainable Investments as described by SFDR (Also known as SFDR-aligned’ Investments)

3. Investments which consider Principle Adverse Impacts on sustainability factors.

*Please see below for an explanation of the above terms

EU Taxonomy-Aligned Investments:

- The EU Taxonomy is a green classification system that translates the EU’s climate and environmental objectives into criteria for specific economic activities for investment purposes.

- An EU taxonomy-Aligned investment contributes substantially to one or more environmental objectives and does no significant harm to any of the remaining environmental objectives.

- The investment is carried out in compliance with minimum social safeguards and complies with (detailed) technical screening criteria established in the Climate Delegated Act.

Sustainable investments as described by the SFDR:

-The SFDR was introduced to improve transparency in the market for sustainable investment products by making the sustainability profile of products more comparable and better understood by end-investors.

-Sustainable investments as defined in the SFDR are investments in an economic activity that contributes to an environmental or social objective.

-This is provided that the investment does not significantly harm any environmental or social objective and that the investee companies follow good governance practices.

Investments which consider Principal Adverse Impacts (PAIs) on sustainability factors:

-The investment considers negative effects on sustainability factors.

-Sustainability factors include environmental, social and employee matters along with respect for human rights, anticorruption and anti-bribery matters.

Please note that the three categories above should not be viewed as a hierarchy of ‘doing good’ as each contributes to a more sustainable world.

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