Sustainable Finance Disclosure Regulation (“SDFR”)

In accordance with the Regulation (EU) 2019/2088, also known as the Sustainable Finance Disclosure Regulation (“SDFR”), ITC International Pensions Limited (“ITCIPL”) is considered a ‘Financial Market Participant’ and therefore is required to provide disclosures on how it considers sustainability risks and the impact of Environmental, Social and Corporate Governance.

Whilst regulation states that ITCIPL is required to disclose on its website whether Principle Adverse Impact (“PAI”) is being considered, ITCIPL does not fall under the scope of such regulation due to the following criteria:

  • The Personal Schemes, are member-directed, meaning that investment decisions are discussed and agreed between the Member and the appointed Investment Advisor or Investment Manager, whilst the Occupational Scheme are non-member directed however the decisions are made by the appointed Investment Manager.
  • All requests are received through an Investment Advisor, and signed by the member, or by the Investment Manager, ITC does not hold an Investment Advice license and concerning this, the company is not responsible and moreover, is unauthorized to provide alternate advice in order to promote ESG as its investment objective.

In this regard, ITCIPL is not required to assess the PAI of whether the underlying investments promote ESG, and whilst we encourage and support the awareness and integration of environmental, social and governance (ESG) factors, it may not always be possible to incorporate sustainability risks into our practices.

We are however, in full support with our current and prospective clients who will take ESG into account in their personal investment policies, as discussed and agreed with their advisors.

Remuneration Policy Disclosure

ITCIPL renumeration policies are independent of variable factors. No variable remuneration is paid to staff unless it is determined to be justified following an internal performance assessment review and/ or cost of living, this is based on quantitative as well as qualitative criteria thus eliminating any undue sustainability risk.