REGULATION

Elgin AMC is a trade name of Numisma Capital Ltd. The company is regulated by the Cyprus Securities and Exchange Commission (CIF licence no. 122/10) and operates in accordance with the Markets in Financial Instruments Directive (MiFID) of the European Union.

Integration of sustainability risks in the investment decision‐process

Sustainability risks represent systemic risks to which the economy as a whole is subject to and are considered as part of the overall risk assessment of the Portfolios that the Company manages or provides Advice. The Company acknowledges that when sustainability risk occurs, there may be a negative impact on its value.

Adverse impacts of investment decisions on sustainability factors

At the moment, except as may be otherwise disclosed on our website, the Company does not consider adverse impacts of investment decisions on sustainability factors. The main reason is actually the lack of information and data which prevents a proper like-to-like comparison between investments in terms of the ESG factors and because this limits the range of available investments under consideration and thus reduces diversification.

Remuneration Policy

Currently Numisma Group does not consider nor make any differentiation on employees’ remuneration when considering sustainability risks. Should the Group consider any changes in the future in its remuneration policy, the website and remuneration policy will be updated accordingly.

The company is also registered with the following:

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