Sustainable Finance Disclosure Regulation (“SDFR”)

May 2023 Disclosures

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 (“ESG)

The 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 (RSA) and Trustee, is required to provide disclosures on how it considers sustainability risks and the impact of ESG factors for all of the schemes it administers.

Personal Retirement Schemes

The Personal Schemes, are all member-directed, meaning that investment decisions are discussed and agreed between the Member and the appointed Investment Advisor or Investment Manager. All requests are received through the Investment Advisor or Manager and signed by the Member. ITCIPL reviews these requests and ensures that the investments are in line with requirements set out in the Pensions Act Chapter 514 and also suitable for the Members investment choice, this being said, that whilst ITCIPL fully supports any initiative taken by the Members provisions and take into account in their personal investment policy as agreed with their advisor in relation to ESG Factors, sustainability risks and PAI, it does not assess the proposed investments to determine whether they have been taken into account or consideration.

ITCIPL also acknowledges that specific disclosures may require to be made by the investment manager or advisor in accordance with the SFDR.

Occupational Retirement Scheme

The Occupational Retirement Scheme is managed by the appointed Investment Manager, meaning that decisions are taken by the Investment Manager in accordance with the investment strategies, and investment restrictions of the Scheme, as set out in the Scheme Particulars, both may be accessed through ITCIPL’s website.

ITCIPL fully supports any initiative taken by the Sponsoring Undertaking of the Occupational Scheme who consider in their personal investment policy as agreed with their advisor, with the approval of the Investment Manager, in relation to ESG Factors, sustainability risks and PAI, it does not assess the proposed investments to determine whether they have been taken into account or consideration.

The Investment Manager does not consider Sustainability Risks, ESG Factors, or the Principal Adverse Impacts of its investment decisions for the following reasons:

  • The Scheme’s principal objective is to always obtain the best possible return for its Members within the Scheme’s stated risk tolerances and regulatory limits. Given the limitation in the variety, number and performance of investments that consider Sustainability Risks, ESG Factors, and PAIs, it is not in the best interest of the Members for the Investment Manager to limit the choice of investments that may be elected for the Scheme.
  • The investment process takes into account the very defined nature of the investment strategy and investment restrictions which already significantly limits the type of investment that the Scheme may be invested in as this is deemed to be in the best interest of the Scheme and its Members.
  • The Investment Manager also takes into account the suitability, income generation and size of individual pensions, and such investments may not be the best decision for the Member’s pension.
  • Any considerations made such adverse impacts, would require the availability and consistency of data, however there may presently still be lacking data reporting. It is thus currently not deemed prudent or practical to incorporate such considerations in the investment decisions.

The Investment Manager may, in the future, consider the application of such considerations of Sustainability Risks, ESG Factors, or Principal Adverse Impacts upon assessment of the Scheme’s size and investment strategy, should such size be deemed to be suitable for, and the investment strategy in the future allows consideration towards such factors.

The Investment Manager may also, in the future evaluate whether to consider Sustainability Risks, ESG Factors, or Principal Adverse Impacts on the basis of availability of tangible data, provided it is adequate to enable inclusion of such factors in its investment decisions.

Renumeration Policy

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.