SWM currently does not manage any funds that are set up in accordance with Art. 8 or Art. 9 of the SFDR.

Art. 3 SFDR regarding the transparency of strategies for dealing with sustainability risks

Financial market participants are required to publish on their websites information on their strategies for incorporating sustainability risks into their investment decision-making processes.

SWM is aware of and sensitized to the growing importance of considering sustainability risks in the investment decision-making process. Appropriate steps are currently planned to implement suitable processes to consider and minimize material sustainability risks.

Art. 4 SFDR regarding transparency of adverse sustainability impacts at the company level

Furthermore, financial market participants are required to transparently disclose adverse sustainability impacts at the company level.

SWM does currently not take such adverse sustainability impacts into account. This is mainly due to the fact that the data of the target companies is currently neither available to a sufficient extent nor in a usable, reliable quality. Nevertheless, SWM is reviewing its further procedure and appropriate options for including sustainability issues in its internal processes.