Sustainable Finance Disclosure

ReAPS Asset Management Limited (“ReAPS”) is appointed as fund manager of APS Funds SICAV plc.

I. Introduction

Below are disclosures by ReAPS which is subject to the EU Sustainable Finance Disclosure Regulation (“SFDR”) in respect of disclosure requirements on investment managers of financial products on the integration of sustainability risk in the investment management process (Article 3) and consideration of principal adverse impacts on investment decisions (Article 4).

II. Integration of sustainability risks

ReAPS is a subsidiary of APS Bank plc which has implemented a policy in respect of the integration of sustainability risk. Sustainability risks refers to an environmental, social and governance (collectively, “ESG”) event, or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. The approach to sustainability risk integration is to identify and assess the ESG risks at an individual issuer level. Non-financial indicators may include, but not limited to, sustainable, ethical and corporate governance issues such as, without limitation, the impact of a company on the environment, the conduct of social and business relationships and governance ethics.

Integration of sustainability risk may vary depending on the strategy, assets and/or portfolio composition of the financial product. This systematic integration of ESG risks in decision-making process relies on: “qualitative assessments”, which will be by reference, but not limited, to case studies, environmental, social and governance impacts associated with issuers, product safety documents, customer reviews, company visits or data from proprietary models and local intelligence; and “quantitative assessments”, which will be by reference to ESG ratings which may be from external providers. However, it should be noted that while ESG risks may be considered in the decision process no one aspect (including ESG ratings) would prevent ReAPS from making any investment as investment decisions remain discretionary and coherent with the mandate of the financial product as disclosed in the relevant offering documents.

III. No consideration of sustainability adverse impacts

Principal adverse sustainability impacts (“PAI”) of an investment decision on sustainability factors refers to the harm that investment decisions may do externally to sustainability factors. ReAPS is required to explain the reasons for not complying with the PAI regime. Presently, ReAPS does not undertake an assessment of the PAIs of an investment decision on sustainability factors at entity-level having regard to issues on data availability and the mandate of the financial product. It is however not precluded that ReAPS may for certain financial products decide to consider PAI on sustainability factors. Where this is the case, more information is available in the offering documents for those financial products. Moreover, this position may be reviewed on an ongoing basis and that ReAPS may adopt for certain financial products an exclusion and/ or positive evaluation screening on underlying investments in relation to certain ESG and sustainability factors as would be disclosed in the offering documents, of the financial product.