In accordance with 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 (the “Regulation”), financial market participants are required to publish on their websites information regarding their policies on the integration of sustainability risks into their investment decision-making processes.
Under the Regulation, sustainability factors mean environmental, social and employee matters, respect for human rights, and anti-corruption and anti-bribery matters.
Accordingly, sustainability risk means an environmental, social, or governance (“ESG”) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.
Where a financial market participant has fewer than 500 employees, it is not required to assess adverse impacts on sustainability at the entity level (management company level), but it must explain the reasons why such assessment is not carried out.
UAB Alpha Asset Management (the “Management Company”) is a small company and therefore does not have the relevant financial and technical resources to consider adverse impacts of investment decisions on sustainability factors at the entity level.
At present, the Management Company manages only those collective investment undertakings that it does not consider sustainable, i.e. whose objective is not sustainable investment and which do not promote social and/or environmental characteristics as defined by the Regulation.
Accordingly, the Management Company does not consider adverse impacts of investment decisions on sustainability factors at the level of the collective investment undertakings.
When making investment decisions, the Management Company seeks to assess all risks and factors that may affect the value and performance of investments, as set out in the Sustainability Risk Assessment Policy for Investment Decision-Making approved by the Management Company. Accordingly, the Management Company evaluates sustainability factors relevant to a particular investment under consideration, as well as the associated risks that may have an actual or potential negative impact on the value of the investment.
In making investment decisions, the Management Company gives priority to investments that are aligned with the European Green Deal approved by the European Commission. Accordingly, attention is paid to the energy efficiency of buildings considered for investment, the potential for renovation and/or improvement of energy efficiency, and the possibilities for the use of renewable energy sources.
Furthermore, the collective investment undertakings intended for informed investors managed by the Management Company will not invest in buildings with an energy performance class lower than A, nor in buildings that, at the time of acquisition, have an energy performance class below A and could not, through reconstruction or renovation, be upgraded to achieve energy performance class A.
The Management Company considers these aspects to the extent that is practical, taking into account its size, stage of development, and its obligation to generate the best possible returns for Investors and to act at all times in their best interests.
In its internal policies, including its Remuneration Policy, and to the extent permitted by the Management Company's size and technical capabilities, the Management Company takes into account the principal adverse impacts of investment decisions on sustainability factors.
However, as noted above, at the level of the collective investment undertaking and in accordance with Article 4(1)(b) of the Regulation, the Management Company relies on the exemption available due to its size and therefore does not formally consider the adverse impacts of investment decisions on sustainability factors, nor does it carry out a detailed assessment of such impacts.
The Management Company has adopted and applies a Remuneration Policy. The purpose of this policy is to ensure that employees of the Management Company are incentivised to manage the risks faced by the Management Company in a sound and effective manner, including sustainability risks.
The Remuneration Policy is published on the Management Company's website at www.aam.lt.
