Disclosure of

ESG Policy

Non-consideration of adverse impacts of investment decisions on sustainability factors.

Article 4 of Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (SFDR) requires financial market participants to ensure transparency as to whether or not they take into account the adverse impacts of their investment decisions on sustainability factors. The Regulation establishes a “comply or explain” principle, depending on whether such impacts are considered, and requires participants to be able to measure the scale of those impacts and disclose the relevant information.

For the purposes of the SFDR, “sustainability factors” include environmental, social, and governance matters, respect for human rights, the fight against money laundering, terrorist financing, the proliferation of weapons of mass destruction, corruption, and bribery.

In carrying out its activities, GEF SGOIC S.A. has approved an Environmental, Social, and Governance (ESG) Policy, which forms part of its Internal Procedures Manual.

Notwithstanding its recognition of the importance of this matter, GEF SGOIC S.A. does not yet take into account the adverse impacts of investment decisions made on behalf of the collective investment undertakings under its management, although it expects to be in a position to do so in the short to medium term.

This declaration of non-consideration of adverse impacts on sustainability factors is therefore issued in compliance with Article 4(1)(b) of the SFDR and Article 12 of Commission Delegated Regulation (EU) 2022/1288.