Sustainability‐related disclosures

Sustainability‐related disclosures

Published: 10.3.2021

Updated: 14.3.2025

Organisation number: 743700OKKV0A8JVAK593

Below are the statutory disclosures according to the EU Sustainable Finance Disclosure Regulation (EU/2019/2088 “SFDR”). According to Article 3 of the regulation, WIP must disclose the principles for considering sustainability risks in investment decisions and investment advice in asset management, and according to Article 5 of the regulation, information on how the remuneration policy is consistent with the consideration of sustainability risks must be disclosed. According to Article 4 of the regulation, WIP must disclose information on whether it considers the principal adverse impacts of investment decisions on sustainability factors.

Integration of sustainability risk

Sustainability risk means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause a negative material impact on the value of the investment.

WIP has integrated sustainability risks by establishing internal policies to ensure that the services provided by the company provide and the funds managed by WIP take sufficient account of sustainability risks.

Procedures for integrating sustainability risks in the investment decision process

We see responsibly operating companies as being more profitable in the long term and having a better risk profile than companies that do not act responsibly. The principles of responsible investment are considered both in our discretionary asset management portfolios and in our investment funds.

WIP integrates sustainability by:

  • Providing portfolio managers with relevant ESG analysis and ratings
  • Enabling to identify sustainability risks and opportunities within the investment universe
  • Integrating sustainability risks into the assessment of investments across all portfolios
  • Considering sustainability risks in investment decision-making process

The capital managed by WIP is vulnerable to sustainability risks and the value of investments may decrease due to sustainability risks. For example, the challenges posed by climate change and the failure to mitigate it may affect the value of investments. For this reason, we have identified the principal adverse impacts and sustainability risks of our investment decisions and consider them when making investment decisions in addition to financial aspects.

Our portfolio managers consider sustainability risks in investment decision-making across all portfolios and funds managed by WIP. There may be differences in the consideration of sustainability risks between different portfolios and funds, as the materiality of sustainability risks varies depending on the asset class, investment strategy, client objectives and market trends.

The portfolio managers have internal and third-party ESG analyses and ratings in place to assess sustainability risks.

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Sustainability risks in the company's remuneration policies

High-quality and responsible asset management is an important part of WIP. High-quality and responsible asset management includes information provided to clients about potential risks to investments, including sustainability risks. WIP’s remuneration policies promote high-quality and responsible asset management.

The variable remuneration to which certain employees are entitled in asset management is linked to the (positive and negative) impact of environmental, social and governance events on the value of investments. The remuneration is tied to specific return targets that tie the investments in asset management to the asset manager’s fee. This supports the integration of sustainability risks into investment decisions.

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Principal Adverse Impacts statement

The principal adverse impacts of investment activities refer to the negative effects that may directly or indirectly arise from the activities of investment objects on the environment, society, or social factors.

No consideration of adverse impacts of investment decisions on sustainability factor

For the time being, WIP does not consider the EU criteria for environmentally sustainable economic activities to be able to disclose principal adverse impacts on sustainability factors of its investments in accordance with the Article 4 of the SFDR or information listed in paragraph 2 of the Article 4.

WIP has made this decision on the basis that the company provides clients with tailored asset management services and for some of the investment strategies it is not possible to conduct detailed due diligence on at least some of the investment targets on the principal adverse impacts on sustainability factors required in SFDR Article 4, paragraph 1, subparagraph a.

We continuously monitor the technical possibilities for assessing, measuring, and reporting the main negative effects of investment objects. When WIP assesses that measurements according to the Disclosure Regulation and its technical standards can be made of investment objects with the accuracy required by the rules, WIP will make a new decision to consider the main negative effects. WIP will reevaluate this regularly.

WIP considers the main negative effects in asset management and investment advice in such a way that the customer decides before and during the customer relationship whether products where these effects are considered should be included in the asset management or in the offered recommendation or investments.

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No consideration of adverse impacts of investment advice on sustainability factors

For the time being, WIP does not consider the EU criteria for environmentally sustainable economic activities to be able to disclose principal adverse impacts on sustainability factors of its investment advice in accordance with the Article 4 of the SFDR or information listed in paragraph 2 of the Article 4.

WIP does not consider the principal adverse impacts of the company’s investment advice on sustainability factors, as there is not enough comprehensive and reliable data for all investment objects to carry out a due diligence process for negative sustainability impacts at the detailed level required by Article 4(1)(a) of the disclosure regulation. Regarding third-party financial products that are subject to investment advice, each actor is responsible for considering sustainability risks and principal impacts in accordance with their own principles.

WIP regularly evaluates the issue and the possibility of considering the potential adverse impacts of its investment advice on sustainability factors. If WIP later determines that it can consider the potential adverse impacts of its investment advice on sustainability factors, this will also be reported later in accordance with Article 4(1)(a) of the SFDR regulation.

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