Sustainability disclosure under Regulation (EU) 2019/2088

“Ever Financial” AD strongly supports all measures aimed at environmental protection, employee rights protection and better corporate governance, which are generally defined as sustainability factors. In this regard, the company has become familiar with the requirements of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of information in relation to sustainability in the financial services sector (Sustainable Finance Disclosure Regulation or SFDR) and the related European regulation.

It should be borne in mind that the license held by the Investment Firm includes the provision of investment services and activities under Art. 6, para. 2, point 4 and point 5 of the Markets in Financial Instruments Act (MFIA), namely “portfolio management” and “investment advice”, but in practice the Investment Firm does not provide these services to professional and non-professional clients, respectively to professional and non-professional investors within the meaning of Art. 2, paragraph 1, point 18 and point 19 of Regulation (EU) 2019/2088.

At present, the Investment Firm does not intend to start offering the investment services and activities of “portfolio management” and “investment advice” to the intermediary’s clients (professional and non-professional investors). Given the fact that the company does not currently offer the services of portfolio management and/or offering investment advice, pursuant to Article 4, paragraph 5.b of the SFDR, the Investment Firm:

➔ currently does not take into account the adverse impacts of investment decisions on sustainability factors, as the investment intermediary does not make investment decisions, because it does not provide portfolio management to professional and non-professional investors.

➔ currently does not take into account the adverse impacts of investment decisions on sustainability factors in its investment advice, because the investment intermediary does not provide investment advice to professional and non-professional investors.

➔ currently does not provide pre-contractual disclosure of information about the financial products it provides, as it does not provide portfolio management to professional and non-professional investors and therefore does not provide the financial product – a managed portfolio in accordance with Article 4, paragraph 1, point 8 of Directive 2014/65/EU.

➔ The Investment Firm also does not provide any other financial products within the meaning of Article 2, paragraph 1, point 12 of Regulation (EU) 2019/2088.

➔ currently does not make pre-contractual disclosures of information about financial products for which it provides advice, as it does not provide investment advice to professional and non-professional investors.

➔ “Ever Financial” AD applies a Remuneration Policy, which aims to establish clear and objective principles for the remuneration of certain categories of personnel and ensure reliable and effective risk management and discourage risk-taking that exceeds the levels acceptable to the investment intermediary in a clear and accessible manner. In connection with Art. 5, paragraph 1 of Regulation (EU) 2019/2088 regarding the transparency of the remuneration policy in relation to the integration of sustainability risks, at present “Ever Financial” AD has not included in its remuneration policy information on how this policy is consistent with the integration of sustainability risks, since the Investment Firm does not take sustainability risks into account, as it does not provide investment advice and portfolio management to professional and non-professional investors.

➔ currently does not take into account the adverse impacts of investment decisions on sustainability factors, as the Investment Firm does not make investment decisions because it does not provide portfolio management to professional and retail investors.

➔ currently does not make pre-contractual disclosure of information about financial products it provides, as it does not provide portfolio management to professional and retail investors and therefore does not provide the financial product – a portfolio managed in accordance with Article 4, paragraph 1, point 8 of Directive 2014/65/EU.

➔ currently, the Investment Firm does not make the declaration under Article 7, paragraph 2 of Regulation (EU) 2019/2088, as for the reasons stated above, it does not disclose information under Article 6, paragraph 3 of Regulation (EU) 2019/2088.

➔ Currently, the Investment Firm does not disclose information under Art. 8, Art. 9, Art. 10 and Art. 11 of Regulation (EU) 2019/2088, as for the reasons stated above, it does not disclose information under Article 6, paragraph 3 of Regulation (EU) 2019/2088.

➔ Currently, Ever Financial AD has not integrated sustainability risks into its investment decisions and investment advice, as it does not provide investment advice and portfolio management to professional and non-professional investors.

If and when the Investment Firm decides to start providing portfolio management to professional and retail investors, then the Investment Firm:

➔ will start to take into account the adverse impacts of investment decisions on sustainability factors and will make the relevant disclosure in accordance with Article 4(1)(b) of Regulation (EU) 2019/2088.

➔ will start to take into account the adverse impacts of investment decisions on sustainability factors and will make the relevant disclosure in accordance with Article 4(5)(b) of Regulation (EU) 2019/2088.

➔ will include in its remuneration policy information on how this policy is aligned with the integration of sustainability risks and will make the relevant disclosure in accordance with Article 5(1) of Regulation (EU) 2019/2088.

➔ will provide the financial product – managed portfolio in accordance with Article 4(1)(8) of Directive 2014/65/EU, and will therefore make pre-contractual disclosure information, in which it will include the information under Article 6(1) and (3) of Regulation (EU) 2019/2088

➔ will make pre-contractual disclosures, which will include the information under Article 6(2) of Regulation (EU) 2019/2088

➔ will make pre-contractual disclosures, which will include the information under Article 6(1) and (3) of Regulation (EU) 2019/2088, as well as the information under Article 7(2), Article 8, Article 9, Article 10 and Article 11 of Regulation (EU) 2019/2088.

➔ will integrate sustainability risks into its investment decisions and investment advice.

Date of publication: 21.04.2021

Date of last review/update: 09.05.2025