Sustainability Policy
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 EAD is committed to sustainable development and responsible investing. Nevertheless, at this stage, we do not consider the principal adverse impacts of investment decisions on sustainability factors.
This document describes the policy of Thracian Invest EAD (the “Company”) regarding the principal adverse impacts of investment decisions on sustainability factors, in accordance with the requirements of Regulation (EU) 2019/2088 and Commission Delegated Regulation (EU) 2022/1288. This policy applies to all investment activities carried out by the Company.
Statement of Thracian Invest EAD on Not Considering the Principal Adverse Impacts of its Investment Decisions on Sustainability Factors
Date of update and publication: 18 June 2026
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 (SFDR) and Section 3 of Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022.
Sustainability Risk Integration Policy
Thracian Invest EAD has adopted and applies a Sustainability Risk Integration Policy within its investment decision-making processes. The policy applies both to the management of the portfolios of the UCITS managed by the Company and to the management of individual client portfolios. The policy is available in the Documents section of our website.
Non-Consideration of Principal Adverse Impacts
Although it applies the policy described above, Thracian Invest EAD does not currently consider the principal adverse impacts (“PAIs”) of investment decisions on sustainability factors within the meaning of Article 4(1)(b) of Regulation (EU) 2019/2088. This applies to the management of the portfolios of the UCITS managed by the Company, the management of individual client portfolios, and the provision of investment advice in relation to financial instruments.
At present, the Company considers that, taking into account the size, nature and scale of its activities, as well as the characteristics of the managed portfolios and funds, there is no necessity to consider principal adverse impacts under Article 4 of SFDR.
The reasons for this decision are as follows:
Limitation of Return and Diversification Opportunities
At this stage, considering the principal adverse impacts of investment decisions on sustainability factors may limit the ability to achieve enhanced returns and portfolio diversification for discretionary portfolio management clients and investors in actively managed UCITS.
High Implementation Costs
The consideration of principal adverse impacts within the meaning of Article 4 of Regulation (EU) 2019/2088 would require significant human, managerial and financial resources without a measurable increase in revenues in the medium or long term.
The implementation of PAI reporting would require additional processes, systems and data sources which, at present, are not proportionate to the nature and scale of the Company’s activities. In this regard, the consideration of principal adverse impacts is currently not aligned with these objectives.
Potential Opportunity Costs
The potential effect of foregone opportunities resulting from investment decisions or investment advice favouring so-called more sustainable products should be capable of being quantified through statistical analysis while ensuring compliance with the investment policy and risk profile of the relevant fund or portfolio and maintaining its targeted risk-return profile.
Incomplete and Unreliable Data from Public Companies
The availability, quality and comparability of ESG data continue to vary significantly across markets, issuers and data providers.
Future Actions
Should Thracian Invest EAD identify a material level of investor demand in the future from investors for whom the consideration of principal adverse impacts on sustainability factors is a priority and takes precedence over portfolio diversification and investment returns, the Company will take the necessary steps to begin considering such impacts.
Periodic Review
The Company reviews, at least annually, its decision not to consider principal adverse impacts on sustainability factors and will update this statement whenever there are changes in the applicable regulatory framework, data availability, or the nature and scale of its activities.
Appendix: Main Regulatory References
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019
Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022
This policy has been approved by the Board of Directors of Thracian Invest EAD and enters into force on 18 June 2026.