This information is provided in connection with the requirements of REGULATION (EU) 2019/2088

Thracian Invest AD’s Declaration on non-consideration of adverse impacts of investment decisions on sustainability factors

Thracian Invest AD is committed to sustainable development and responsible investing. However, at present, we do not take into account the principal adverse impacts of investment decisions on sustainability factors.

This document outlines the policy of Thracian Invest AD (the Company) regarding the principal adverse impacts of investment decisions on sustainability factors, in compliance with the requirements of Regulation (EU) 2019/2088 and Delegated Regulation (EU) 2022/1288 of the European Commission. This policy applies to all investment activities carried out by the Company.

Declaration by Thracian Invest AD regarding non-consideration of adverse impacts

Date of update and publication of the declaration 18/06/2024

Introduction:
This document provides information in accordance with Article 4 of 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 and Section 3 of Delegated Regulation (EU) 2022/1288 of the Commission of 6 April 2022.

Policy on integration of sustainability risks:
Thracian Invest AD has adopted and adheres to a Policy for the Integration of Sustainability Risks in investment decision-making processes. This policy applies to both the management of portfolios of Undertakings for Collective Investment in Transferable Securities (UCITS) managed by the Company and the management of individual client portfolios. The policy is available in the Documents section on our website.

Non-consideration of adverse impacts:
Although the Company implements the aforementioned policy, Thracian Invest AD does not take into account the adverse impacts of investment decisions on sustainability factors as per Article 4(1)(b) of Regulation (EU) 2019/2088. This applies to the management of UCITS portfolios, individual client portfolios, and the provision of investment advice. The reasons for this decision are as follows:

Limitations on return and diversification opportunities:
Accounting for adverse impacts at this stage could limit opportunities for achieving better returns and diversification for trust management clients and UCITS investors.

Lack of Client Demand:
The Company provides clients the option to impose investment restrictions, including prioritizing sustainability risks. However, to date, no client has expressed interest or requested such prioritization.

High Implementation Costs:
Implementing the consideration of adverse impacts would require significant resource expenditure (human, managerial, and financial), which would not yield measurable revenue increases in the medium or long term.

Lack of Standardized and Accessible Disclosure Mechanisms:
Public companies currently lack regulated and accessible disclosure methods for ESG data, making it challenging to form objective insights about sustainable factors.

Potential Missed Opportunities:
Potential missed investment opportunities due to prioritization of sustainability could impact the risk/return ratio for funds and portfolios.

Incomplete and Unreliable Data from Public Companies:
The absence of guarantees regarding the accuracy and comparability of ESG data from public companies.

Ongoing Development of the Legal Framework:
The European regulatory framework for sustainability disclosures is still under development, creating uncertainty.

Future Actions:
If, in the future, Thracian Invest AD identifies significant demand from investors prioritizing the consideration of adverse impacts over diversification and returns, the Company will take steps to integrate these considerations into its processes.

Appendices: Key Regulatory References
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019.
Delegated Regulation (EU) 2022/1288 of the Commission of 6 April 2022.

This policy has been approved by the Board of Directors of Thracian Invest AD and is effective from 18 June 2024.

The Policy for Mainstreaming Sustainability Risks