SFDR - Sustainability-Related Disclosures

The disclosures below explain the details of how AIM Capital complies with the disclosure requirements in accordance with the European Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”).

Policies on the Integration of Sustainability Risks

AIM Capital takes into account the adverse impacts of sustainability risks regarding the AIM Diversified Strategies Sub-Fund to the extent that such risks form an intrinsic part of other risks, such as market risk and operational risk AIM Diversified Strategies Sub-Fund invests to the financial products that do not promote environmental or social characteristics or have sustainable investment as an objective.

As AIM Diversified Strategies Sub-Fund does not promote environmental or social characteristics or have sustainable investment as an objective, AIM Capital considers that the best interests of the Fund’s investors are served by following the investment objectives and policies of the Fund.

No consideration of principal adverse impacts of investment decisions on sustainability factors

AIM Capital do not consider principal adverse impacts of investment decisions on sustainability factors regarding the AIM Diversified Strategies Sub-Fund (“PAI”). AIM Capital considers this a pragmatic and economical approach to compliance with its obligations under the SFDR, given the nature scale and complexity of the AIFM and because the relevant data available to it is not reliable enough to allow it to take PAI into account in investment decisions at this time. The AIFM continue to monitor data available to it in respect of PAI with the aim of implementing the consideration of adverse impacts in conjunction with application regulatory deadlines.

Extract from remuneration policy regarding sustainability integration

The company’s remuneration policy seeks to ensure that the remuneration (fixed and variable) paid to employees promotes effective risk management while not encouraging excessive risk-taking. To be able to ensure this, the policy contains guidelines on how the company seeks to identify, measure, govern, internally report and control the risks associated with remuneration systems in our business.

It is of importance to AIM Capital that the employees integrate ESG-thinking into applicable parts of the investment process. Employees are encouraged to seek new and better ways to improve work with sustainability risks and adverse impacts in the investment process. Employees are also encouraged to pursue new and improved ways to create ESG-friendly products and services.

Employee efforts that lead to either the identification of new sustainability risks or the company being able to mitigate adverse sustainability impact, are endorsed by the company. Such efforts among others are to be taken into consideration when variable remuneration is being considered. By linking ESG issues to remuneration the company hopes to achieve financial impact on employees whose compensation is linked with ESG measures, driving better ESG performance.