Sustainable Finance Disclosure Regulation

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The following disclosure statement relates to Utmost PanEurope dac.

Under Regulation (EU) 2019/2088 of the European Parliament and of the Council (the “SFDR”), Utmost PanEurope dac (“UPE”) is required to make certain disclosures about how it integrates sustainability risks into its investment decision-making process and how it considers adverse impacts of its investment decisions on sustainability factors.

Sustainability risk is defined as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. Sustainability factors mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

In relation to its investment-based insurance products, UPE plays a passive role regarding policyholder investments, does not make investment decisions for policyholders, nor does it play a role in recommending or advising on investment selection.

Accordingly, UPE does not consider any adverse impacts of its investment decisions on sustainability factors.

Where UPE offers the policyholder the ability to direct the investment choice on a product, either via a list of funds approved by UPE, or on an open architecture basis, the policyholder, or their adviser, is responsible for the investment choice and setting the appropriate investment strategy. UPE invests in the underlying investments in accordance with this investment choice.

Where UPE’s investments are managed on a discretionary basis, management of those investments may be delegated to a number of regulated discretionary asset managers. In a small number of cases, UPE may appoint an investment adviser who would advise on investment choice, in accordance with an investment strategy chosen by a policyholder. In those cases, UPE would authorise the recommendation and transmit to the relevant custodian for execution, based on the investment adviser’s advice.

UPE’s investments have been selected by discretionary asset managers or, in a small number of cases, on the basis of advice from an investment adviser, who ensure that investment decisions or recommendations are aligned to the risk profiles and investment objectives of UPE’s policyholders. Accordingly, UPE does not actively engage with investee companies in its portfolios and relies on its appointed asset managers to do so.

UPE may set or describe a ‘standard’ investment strategy that policyholders may select. However, UPE will delegate the portfolio management of that strategy to its appointed discretionary asset manager or, in a small number of cases, appoint an investment adviser who will advise on the portfolio management.

Therefore, as UPE does not make investment decisions, it does not integrate sustainability risk into its investment decision-making process or consider adverse impacts of investment decisions on sustainability factors.

Customers should consult their professional advisers to understand how sustainability risk and sustainability factors may be integrated into their investment choices.

Remuneration Policy

As part of Utmost Group, UPE follows a remuneration policy that incorporates and promotes sound and effective risk management linked to risk-adjusted performance. UPE’s remuneration policy remains consistent with its position on the integration of sustainability risks as outlined above.

Date of Publication: 10 March 2021

Last updated: 30 June 2022