No considerations

It follows from Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the Disclosures Regulation) that financial market participants must disclose whether considerations of adverse impacts on sustainability factors are included in their investment decisions.

Pursuant to Article 4(1)(b), financial market participants, including managers of alternative investment funds, which do not consider adverse impacts of their investment decisions on sustainability factors, must publish clear reasons for why they do not do so on their websites.

DEAS Fund Management is dedicated in preserving its values and ensuring prudent and sustainable economic growth by addressing our concerns for the future today. The manager’s strategy is tied to the UN’s sustainable development goals in relation to sustainable cities and communities as well as decent jobs and economic growth.

DEAS Fund Management has however assessed that the preparation of the comprehensive document requirements for compliance with the EU requirements will not in itself have a beneficial sustainability-related effect relative to our current performance. We find that seeing that the preparation of the documents will not in itself contribute to more sustainable investments, our investment products should not be made more expensive through increased costs for compliance with detailed regulatory document requirements.

We must therefore disclose that, in accordance with the definition in Article 4(1)(b) of EU Regulation 2019/2088, we do not take into consideration adverse impacts of our investment decisions on sustainability factors.

DEAS Fund Management will continuously monitor the technical possibilities for screening, measuring, and reporting on specific sustainability factors. Once we deem that the specific measurements found in the EU regulations can be made with the requisite level of certainty and the associated costs stand proportionate to the reporting, DEAS Fund Management will update its policies accordingly.

If the Danish Financial Supervisory Authority issues any guidelines for the extensive document requirements, we will assess whether the costs of compliance with these requirements are commensurate with our investors’ wishes for document requirements.