SFDR & Sustainability related Disclosures
A. Entity-level Website Disclosures
Regulation (EU) 2019/2088 of 27th November 2019 on sustainability-related disclosures in the financial services sector, as amended (“SFDR”) governs the transparency requirements regarding the integration of sustainability risks into investment decisions, the examination of adverse impacts on sustainability and the disclosure of Environmental, Social and Governance (“ESG”) and sustainability-related information with respect to financial products.
CISCO provides the investment services of Portfolio Management and Investment Advice, therefore it falls under the definitions of both a Financial Market Participant and a Financial Adviser, respectively, as per the SFDR, and as such, it has the relevant obligations set forth in this notification.
Currently the Asset Management Team, invests primarily in UCITS funds, some of which take into consideration environmental and social characteristics, and thus fall under Article 8 of the SFDR. Moreover, CISCO has partnered with Schroders to offer Model Portfolio solutions developed to meet client investment objectives that incorporate sustainability preferences. The portfolios offered are actively managed, investing in funds across the sustainability spectrum including integrated, screened, sustainability themed and impact strategies.
With respect to Portfolio Management services, the Company integrates sustainability risks into investment decisions by incorporating ESG factors into the analysis of constituents in the portfolios offered to clients, employing ESG due diligence and screening criteria, amongst other tools. For instance, a proprietary research tool developed by Schroders puts a financial value on the potential costs and benefits that companies and countries have on society and allows our Asset Management Team to integrate these risks and considerations into their investment decision-making process. Each cost or benefit measured by the proprietary tool can also be mapped to a relevant United Nations Sustainable Development Goal (UN SDG) category.
In regard to Investment Advice services, the Company does not consider the integration of sustainability risks within its investment advice, given that the aforementioned Model Portfolios are only provided under the Company’s discretionary Portfolio Management service offering, in partnership with Schroders. Therefore, at the current moment, CISCO possesses limited data and dedicated expertise to consider the integration of sustainability risks into investment advice.
Commission Delegated Regulation (EU) 2022/1288 of 6th April 2022 supplements the SFDR on the content and presentation of relevant disclosures. As such, CISCO has prepared dedicated disclosures for each financial product offered that promotes environmental or social characteristics and hence falls under Article 8 of the SFDR.
Moreover, the Company does not, as things stand, take into account the EU classification criteria under the Taxonomy Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investments, in terms of the investment services it offers.
CISCO is integrating sustainability risks into its remuneration framework in alignment with the group’s broader approach. The remuneration policy promotes sound and effective risk management, in line with the Group’s ESG and climate strategy and does not encourage excessive risk taking that exceeds the level of risk tolerated by the Group. Remuneration structure typically consists of fixed plus variable pay. Fixed remuneration does not embed any ESG incentive considerations. Variable remuneration is based on a combination of the performance of the employee, the overall performance of the business and the Group’s consolidated financial results.
CISCO, taking account of its size and the nature, complexity and scope of the activities it offers and the types of financial products that the Company advises on, does not currently consider any negative impacts of investment decisions on sustainability factors. The Company will keep its decision not to consider PAIs of investment decisions under regular review and will formally re-evaluate the decision at least annually.
Should CISCO reassess its consideration in regard to adverse impacts in the future, or if there are any updates in relation to products offered by the Company that may fall under Article 8 and/or Article 9 of the SFDR, then this notification shall be updated accordingly.
B. Entity-level PAI Disclosures
No consideration of adverse impacts of investment decisions on sustainability factors
CISCO, in its capacity as a Financial Market Participant, and taking account of its size and the nature, complexity and scope of the activities, it offers, does not currently consider principal adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of Regulation (EU) 2019/2088 (the Regulation on Sustainability-Related Disclosures in the Financial Services (“SFDR”)).
Although CISCO takes sustainability and ESG very seriously, it is noted that some of its investment strategies cannot currently support the adoption of the adverse impacts' regime within SFDR, given that these strategies involve mainly investing in mutual funds, where it is often not possible to conduct detailed diligence on the principal adverse impact of our investments on sustainability factors.
The Company will keep its decision not to consider PAIs of investment decisions under regular review and will formally re-evaluate the decision at least annually. Should CISCO reassess its consideration in regard to adverse impacts in the future, this notification shall be updated accordingly, in line with Article 12 of Commission Delegated Regulation (EU) 2022/1288.
02/06/2025
No consideration of adverse impacts of investment advice on sustainability factors
CISCO, in its capacity as a Financial Adviser, and taking account of its size and the nature, complexity and scope of the activities it offers and the types of financial products that the Company advises on, does not currently consider principal adverse impacts of investment decisions on sustainability factors in its investment advice in the manner prescribed by Article 4 of Regulation (EU) 2019/2088 (the Regulation on Sustainability-Related Disclosures in the Financial Services (“SFDR”)).
Although CISCO takes sustainability and ESG very seriously, it is noted that some of the investment strategies it advises on cannot currently support the adoption of the adverse impacts' regime within SFDR, given that these strategies involve mainly investing in mutual funds, where it is often not possible to conduct detailed diligence on the principal adverse impact of our investment advice on sustainability factors.
The Company will keep its decision not to consider PAIs of investment decisions under regular review and will formally re-evaluate the decision at least annually. Should CISCO reassess its consideration in regards to adverse impacts in the future, this notification shall be updated accordingly, in line with Article 13 of Commission Delegated Regulation (EU) 2022/1288.
02/06/ 2025