No Consideration of Sustainability Adverse Impacts

Integrating Sustainability Risks in Investment Advice

PAIs (Principal Adverse Impacts) are those impacts arising from a particular investment decision taken / personal investment recommendation made, that will eventually have a negative effect on Environmental, Social & Governance (‘ESG’) Factors.

In view of the fact that the Bank provides advisory services and makes recommendations to customers based upon a pre-approved investment products list, the Bank does not consider the adverse impacts of investment decisions on sustainability factors when providing investment advice.

Responsible and Sustainable Investing policy

Notwithstanding the above, the Bank’s product suite contains a subset of investments that, as part of their main strategy, place an important weight on ESG Factors in their investment allocation decision making process.

We will actively engage with our customers to understand whether they have concerns about investing in financial instruments related to specific activities and / or industries with negative impact on ESG factors, in order to exclude, as far as possible, such financial instruments when making personal investment recommendations.

Alignment of Remuneration Policy with sustainability investments

In line with our Remuneration Policy, no variable remuneration is paid to our staff unless it is determined to be justified following a performance assessment based on quantitative as well as qualitative criteria. In any case, the quantitative assessment does not take into consideration the amount of sales or the specific products purchased resulting from personal investment recommendations.