Sustainable Finance Disclosure Statement (“SFDR”)

Responsible and Sustainable Investing

We do not assess Environmental, Social and Governance (“ESG”) Factors that may have investment ramifications, and which may have a material impact on the investment’s long-term financial performance. As a result, information on ESG Factors does not form part of our investment decision making process.

Negative and positive screening

We may, at our discretion, actively engage with our clients to understand whether they have concerns about specific activities and / or industries in order to exclude such investments on an on-going basis. In such cases, we undertake – to the extent possible – to screen target entities and /or products that promote and provide solutions that are consistent with ESG Factors and, shall aim at recommending / and or investing in such products on an on-going basis, in so far as possible.

Exclusions

We will not knowingly invest in entities involved in the following activities:

• arms manufacturing;
• manufacture of tobacco;
• hard spirits; and
• gambling.

We will assess these types of investments on a case-by-case basis and any potential for indirect exposure is carefully considered and factored into investment selection.

Principle Adverse Impacts

We do not undertake an assessment of the Principal Adverse Impacts (“PAIs”) of our decisions on ESG Factors. PAIs are those impacts arising from a particular decision taken which we take that will eventually have a negative effect on ESG Factors.

Kindly contact info@levelecapital.com for a full copy of our ESG Policy.