Date of last update: October 16, 2023

Since the Sustainable Finance Disclosure Regulation came into effect, provide financial market participants such as Wellscott insight into how it manages sustainability into its investment decisions.

Sustainability Risks

Investments may be exposed to Sustainability Risks. Examples of such events or circumstances include climate change, involvement in child labor, or scarcity of raw materials. Such events and circumstances could have a negative effect on the value of investments.

Wellscott assesses Sustainability Risks as any other risks such as market risk. All of these risks could result in the possibility that expected or targeted returns may not be achieved.

By integrating risk factors – including sustainability factors - into the investment decision process Sustainability Risks are managed by Wellscott. If Wellscott identifies high risks - including sustainability risks - Wellscott will not invest or replaces an existing investment

No Consideration of Principal Adverse Impacts

Wellscott does not consider principal adverse impacts of its investments decisions on sustainability factors at entity level. As the Fund Manager is required to assess all indicators of Table 1 of Delegated Regulation 2022/1288 as well as the relevant indicators of Tables 2 and 3 if it were to include negative impacts on sustainability factors at entity level the Fund Manager believes that there is currently insufficient reliable data available to adequately analyze all of these negative impacts and integrate them into its investment process.

Wellscott takes into account some principal adverse impacts on sustainability factors for GSELS SQE.

Wellscott will follow developments in this area closely and reconsider the above statement if it appears that sufficient reliable data becomes available in the market.

Remuneration and sustainability risks

Wellscott’s remuneration policy is aimed at retaining qualified staff, to reward ethical behaviour, to manage risks - including sustainability risks- , sound management of its funds and treating its investors fairly. No variable payments are awarded.