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, as a retirement scheme administrator, does not deem applicable in its investment decisions in light of the following:

• 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 in line with the Investment Principles, with the oversight of ITCIPL as trustee of the Scheme.
• 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.
• ITCIPL can only refuse to give effect to the member’s directions in very limited circumstances, such as when the choices made are not in line with the Pensions Act Chapter 514. As a result,  ITCIPL is not in a position to undertake an assessment of the PAIs of its investment decisions on sustainability factors.

In this regard, ITCIPL does not consider PAI of 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 and also acknowledge that specific disclosures may require to be made by the investment manager or advisor in accordance with the SFDR.

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.