Aristeus provides portfolio management and investment advice services in accordance with the relevant legislations governing the Company. As a principle, Aristeus puts the interest of clients’ private portfolios first and ensures market integrity. On the basis of the above, Aristeus also considers the assessment of sustainability risks as part of the Company’s wider investment decision-making process, meaning that an identification of one or more sustainability risks alone will not generally preclude the Company from pursuing an investment where such investment is otherwise assessed to meet the investment criteria. For the assessment of ESG factors, Aristeus relies solely on third-party data providers.

Aristeus has elected currently not to consider the adverse impacts of investment decisions on “sustainability factors” as specifically required by SFDR, due to the size of its operations and the absence of regulatory guidance and available, accessible, relevant and comparable data to perform the adverse impact assessment.

Aristeus continue to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance, and will be updating its policies in line with the relevant requirements.

The Company’s remuneration policy is structured in a manner which promotes sound risk management and does not encourage excessive risk-taking. Therefore, it is not currently expected to make any changes in the remuneration policy in relation to sustainable risks.