SFDR (Sustainable Finance Disclosure Regulation)

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”) seeks to achieve transparency with regards to the integration of sustainability risks and the consideration of adverse sustainability impacts in the processes of financial market participants and financial advisers and the provision of sustainability-related information with respect to financial products.

Van Sterling Capital Ltd. (“the Company”) is considered to be a Financial Market Participant in terms of the SFDR and is therefore required to disclose information about its policies on the integration of sustainability risks in its investment decision-making process.

No Consideration of Sustainability Factors

The Company aims to consistently take investment decisions in a highly professional manner and in the best interests of its clients, based on its market knowledge, experience and access to research and also on the basis of a medium or long-term investment horizon.

Whilst the Company recognises the growing importance of sustainability in investment management processes, the Company has deemed that, due to its relatively small size and scale of activities, it shall not currently consider principal adverse impacts of its investment decisions on sustainability factors. Nevertheless, the Company does not rule out such considerations in the future. Indeed, the Company shall ensure that any information it publishes in relation to SFDR is kept up to date, and where any such information is amended, a clear explanation of such amendment shall be disclosed accordingly.

Remuneration Policy and Integration of Sustainability Risks

The Company offers transparency and consistency in its remuneration strategy. There are no incentive related fees or sales related commissions. Indeed, all staff members are rewarded by means of fixed remuneration, thereby ensuring that the remuneration structure does not encourage risk-taking with respect to sustainability risks. Consequently, the Company does not consider its remuneration policy to be inconsistent with the integration of such risks.

Pre-contractual Disclosures

The Company shall ensure that the disclosures required in terms of the SFDR are disclosed to the client or potential client, in good time. The Company shall also ensure that any material changes to the SFDR disclosures are communicated to the investors accordingly.

Marketing Communications

The Company shall ensure that its marketing communications do not contradict the information disclosed pursuant to the SFDR.