Sustainable Finance Disclosure Regulation (“SFDR”)

Sustainability Risks 

“Sustainability Risks” as defined in Article 2(22) of the 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: “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment”.

Sustainability Risks include (but are not limited to) the following:

• environmental risks such as the impact of environmental events such as carbon pricing, climate change vulnerability and biodiversity;
• social risks such as impact of non-compliance with anti-slavery or working conditions laws and regulations by portfolio companies; and
• governance risks such as board composition and remuneration and regulatory and tax compliance.

Integration of sustainability risks in investments decisions (Article 3 SFDR)

GuildAM Ltd (“GAM”/the “Company”) aims to investigate sustainability risks during investment due diligence/investment advice and consider material sustainability risks when making investment decisions. Sustainability risks are also investigated during ongoing review of the portfolios.

GAM’s approach to investigating and addressing sustainability risks is tailored to each investment strategy/investment advice, taking into consideration factors such as asset class, geography, and industry.

Principal Adverse Sustainability Impacts Statements (Article 4 SFDR)

No consideration of adverse impacts of investment decisions on sustainability factors

GAM does not consider the Principal Adverse Impacts (PAI) of investment decisions on sustainability factors to the extent that is required by Article 4(1) of the Regulation. By taking into consideration the Company’s size, the nature and scale of its activities and the types of clients it has onboarded and their investment strategy, the Company considers that it would be disproportionate to consider principal adverse impacts as set out in the PAI regime in the SFDR.

Nevertheless, the Company may consider such principal adverse impacts in the future should there be increased interest from clients and should attractive opportunities be presented. The Company shall re-assess its position on at least an annual basis.

Remuneration and sustainability risks (Article 5 SFDR)

GAM’s Remuneration paid out to staff is not linked to sustainability related KPIs. Due to this very limited impact on the risk-profile of our clients, as well as the nature of our business,

Kindly contact compliance@guildam.com for further information.

March 2025