EXPLANATION OF NON-COMPLIANCE
WITH SFDR´S PRINCIPAL ADVERSE IMPACTS REGIME
by MIO-Partners (EU) GmbH
As a regulated investment firm holding a license to provide investment advisory and portfolio management services within the EU, MIO-Partners (EU) GmbH (Legal Entity Identifier (LEI): 549300HJRK3DG97HGY53) (hereinafter referred to as: ”we”) is subject to the requirements set by the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (hereinafter referred to as “SFDR”). SFDR requires us to make a “comply and explain” decision whether to consider the principal adverse impacts of our investment decisions or investment advice on sustainability factors in accordance with the specific regime as outlined in SFDR (“PAI regime”). Under SFDR, “Sustainability Factors“ are defined as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
No consideration of adverse impacts
Regarding the provision of investment advisory services (as a financial adviser):
We do not consider the adverse impacts of investment decisions on Sustainability Factors in our investment advice. We do also not intend to consider such adverse impacts in the future, since we only provide the service of investment advice with respect to a clearly defined set of financial products. It is up to the investor to decide on an investment in the relevant financial product on the basis of the information made available in the subscription documents. We are also aware of the lack of public, readily available and/or cost-effective data to comply with the technical reporting requirements of the PAI regime. However, we will at least on an annual basis revisit our decision not to comply with the PAI regime and reserve the right to change our position in the future.
Regarding the provision of portfolio management services (as a financial market participant):
We do not consider the adverse impacts of our investment decisions on Sustainability Factors. We do also not intend to consider such adverse impacts in the future, since we only provide the service of portfolio management to a very limited number of institutional investors within a clearly defined investment policy. We are also aware of the lack of public, readily available and/or cost-effective data to comply with the technical reporting requirements of the PAI regime. However, we will at least on an annual basis revisit our decision not to comply with the PAI regime and reserve the right to change our position in the future.
Transparency on the integration of a sustainable risk policy
In accordance with applicable law and legislation, we have integrated in our firm processes to provide our clients with appropriate guidance on and warnings of all relevant kinds of risks (including, where relevant, Sustainability Risks) associated with the investments or financial products we advise on or make available to them. However, for the time being, we have not implemented a specific policy on the integration of Sustainability Risks in our investment decision making and/or the investment advice we provide. Consequently, besides our general risk management processes, we have not implemented any specific measures to assess the likely impacts of Sustainability Risks on the returns of the financial products we advise on in particular. For these purposes, SFDR defines “Sustainability Risk“ 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 an investment.
The main reason for this is that our product providers and/or manufacturers do currently not provide sufficient information on the specific impact of Sustainability Risk on the returns of their products based on which we could make such assessment. Therefore, as a rule, we cannot exclude that Sustainability Risk may have a particular and/or significant impact on the investments or financial products we make available or advise on.
Last updated August 23rd, 2022