Sustainability-Related Disclosure of Information EU

Ever Financial AD strongly supports all measures aimed at protecting the environment, employees’ rights and corporate governance of the companies, which are generally identified as sustainability factors. In this regard, Ever Financial AD became acquainted with the requirements of the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation or SFDR) and the related European regulation.

However, for the time being and referring to Article 4, paragraph 5.b of the SFDR, at this stage Ever Financial AD has chosen not to consider adverse impacts of investment decisions on sustainability factors in its investment advice and during the portfolio management for the following reasons:

• The legal framework at both European and national level is still evolving.

The regulatory technical standards under the SFDR are still a draft.

The existing regulation is divided between different European acts which were adopted at different times and which are not fully coordinated.

The modification of MiFID II is still pending. The national legislation, which will introduce measures to implement the EU regulation, has not yet been adopted.

• Lack of information from issuers.

Currently, only some large issuers are required to disclose non-financial information that is relevant to sustainability factors and however, the information they are obliged to disclose is not sufficiently detailed.

The EU rules related to disclosure of non- financial information do not apply to issuers from third countries.

The Company must have a secure and reliable source of data in order to be able to consider the sustainability factors in its investment advice and portfolio management services.

• Consideration of sustainability adverse impacts requires the revision of many of the internal rules and policies of the Company, which will consume a lot of time and efforts especially taking into account that the legal framework is still incomplete.

Ever Financial AD applies a Remuneration Policy, which aims to establish clear and objective principles of remuneration of certain categories of staff and to ensure reliable and effective risk management and non-promotion of risk-taking that exceeds those acceptable to the investment intermediary levels. The Company believes that even after the integration of sustainability risks in the investment decision-making process in the portfolio management services and investment advice services, this will not adversely affect the reliable and effective risk management and non-promotion of the risk of the Company.

In order to decide to consider sustainability factors, the Company must first review and revise all its internal rules and policies and adopt the necessary changes, especially in the risk management rules and remuneration policy. Given the fact that the legal framework is under development, this process of revising the internal rules cannot be completed in short period of time.

At present, the size of activity of the Company as well as the nature and scale of its activities, especially those related to investment advice and portfolio management services, does not justify taking further administrative measures and costs.