Sustainability

Pure Capital is duly informed of the obligations and requirements relating to sustainable economic activities stemming from the SFDR and Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment and amending Regulation (EU) 2019/2088 (the “Taxonomy Regulation”).

The Regulation establishes harmonized rules for investment funds on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes and the provision of sustainability information.

Environmental, social and governance (“ESG”) issues may represent a risk defined as an event or situation in the ESG fields which, if it occurs, could have a material adverse impact, actual or potential, on the value of the investments.

It should be noted that the legal framework and factors to consider in assessing the sustainability of an investment are still under development at European level. This lack of common standards may lead to a divergence between actors in their respective approaches to this matter and thus introduce a certain subjectivity by the same actors in the matter related to the ESG fields. ESG information, whether from an external and/or internal source, is, by nature and in many instances, based on a qualitative and judgmental assessment, especially in the absence of well-defined market standards and due to the existence of multiple approaches to sustainable investment. An element of subjectivity and discretion is therefore inherent to the interpretation and use of ESG data. It may consequently be difficult to compare strategies integrating ESG criteria. ESG information from third-party data providers may be incomplete, inaccurate or unavailable, which may adversely impact a Portfolio placing reliance on such data for the purposes of assessing the appropriate inclusion or exclusion of a security.

The sustainability risks are being monitored by the Management Company.

• Some sub-funds may not take into account the adverse impacts of investment decisions on sustainability factors and does not take into account sustainability risks into the investment decisions since the consideration of ESG criteria is not part of the portfolio management strategy of these sub-funds ("Article 6" sub-funds). Article 7 of Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainability investment (the "Taxonomy Regulation") applies to these Sub-funds. The investments underlying these financial products do not take into account the EU criteria for environmentally sustainability economic activities.
• Other Sub-funds may be classified under article 8 or 9 of the SFDR. For these Sub-funds, additional information regarding the likely impact of the sustainability risk on the investment will be provided in the prospectus and on the website based on the additional procedures that will be included into the risk management plan relating to the fund.

For more information, you should refer to the respective webpage of the different funds/sub-funds: UCITS | Pure Capital

The approach to sustainable finance may evolve and develop over time, both due to a refinement of investment decision-making processes to address ESG factors and risks, and because of legal and regulatory developments. This document and/or the website of the Management Company and of the Investment Managers may be updated to include additional information.