ESG Policy

Our Sustainability Approach

Integration of ESG Criteria and Sustainability Risks

Sun Hill Investment Management considers environmental, social and governance (“ESG”) criteria as part of its overall investment analysis and risk assessment process because it believes this analysis is critical in order to have a complete understanding of the risk of each investment.

We define a sustainability risk as an ESG event or condition that, if it occurs, could cause a material impact on either the investment risk or return of our funds or portfolios.

ESG risks may impact the strategy of our funds and can have negative impacts on the overall performance of our funds, hence it is imperative for us to understand how these issues affect business strategy and performance. Impacts from these issues can be financial, material, and can spread across multiple funds and managed portfolios.

We adopted good governance practices, our Board composed of a mix between independent and non-independent directors, to limit bias which may otherwise lead to board approvals risks. Additionally, we have a social objective and adopted an inclusivity HR approach and appointed personnel with different nationalities and genders.

The offering documents of our funds include disclosures on the policies in place to integrate sustainability risk.

We do not follow a mechanistic, formulaic approach to determine which sustainability risks might be most material, but instead assesses those risks on an item-by-item and investment-by-investment basis taking into account available information and data. As such, Sun Hill Investment Management considers sustainability risks to varying extent depending on factors such as the availability and type of ESG data, the investment horizon and the characteristics of the investment.

Whilst Sun Hill Investment Management engages in the assessment of ESG criteria as described above, it does not have formal quantifiable targets or hurdles for all of its funds and portfolios under management.

Principle Adverse Impacts (“PAIs”)

No consideration of adverse impacts of investment decisions on sustainability factors

At the moment, the fund does not consider PAIs due to its size and nature. The fund is considered small and invests exclusively in a block of apartments in Budapest, with this being its sole objective for the foreseeable future. Therefore, since the fund was not created to have, and does not intend to have, a diversified portfolio of investments, but rather various apartments and other property in the same block, it does not deem appropriate to carry out an assessment of adverse impacts of investments.

Remuneration Policy

In line with the Remuneration Policy of the Company, no variable remuneration is paid to the staff unless it is determined to be justified following a performance assessment based on quantitative (financial) as well as qualitative (non-financial) criteria.

Due to the nature of its business, Sun Hill Investment Management (Malta) Ltd deems that there is no risk of misalignment with the integration of the sustainability risks, if any, in its investment decision making process of the Company with respect to the Collective Investment Schemes.

As such, the Company believes that its existing structures are sufficient to prevent excessive risk taking in respect of sustainability risks.