Article 3: Transparency and Integration of Sustainability Risks

Sustainable and ESG investing is about integrating non-financial factors and good governance in investment processes and in the underlying investments to an investment strategy to, alongside financial return, also generate positive social and environmental impact.

In general, sustainable finance is a relatively new field of finance. Currently, there is no universally accepted framework or list of factors to ensure that investments are sustainable. Also, the legal and regulatory framework governing sustainable finance is still under development. The lack of common standards may result in different approaches to setting and achieving ESG objectives. ESG factors may vary depending on investment themes, asset classes, investment philosophy and subjective use of different ESG indicators governing portfolio construction.

The selection and weightings applied may to a certain extent be subjective or based on metrics that may share the same name but have different underlying meanings. ESG information, whether from an external and/or internal source, is, by nature and in many instances, based on a qualitative and judgmental assessment, especially in the absence of well-defined market standards and due to the existence of multiple approaches to sustainable investment. An element of subjectivity and discretion is therefore inherent to the interpretation and use of ESG data. It may consequently be difficult to compare strategies integrating ESG criteria. Investors should note that the subjective value that they may or may not assign to certain types of ESG criteria may differ substantially from that of the Sub-Fund.

ESG information from third-party data providers may be incomplete, inaccurate or unavailable. As a result, there exists a risk of incorrectly assessing a security or issuer, resulting in the incorrect inclusion or exclusion of a security. ESG data providers are private undertakings providing ESG data for a variety of issuers. The ESG data providers may change the evaluation of issuers or instruments, at their discretion and from time to time, due to ESG or other factors.

For the reasons outlined above, sustainability risks are not integrated into the investment decisions and/or advice provided by the Company.  The Company believes that integrating such risks into the investment decisions and/or advice shall create delays in taking decisions, as a result of the lack of clarity and increased reporting requirements as outlined earlier in this section, may significantly limit the investment universe from which the Company can make its investment decisions and/or provide advice, and can result in a disadvantage to investors in terms of performance. 

The approach to sustainable finance may evolve and develop over time, both due to a refinement of investment decision making processes to address ESG factors and risks, and because of legal and regulatory developments.

Article 4: Principal Adverse Impacts

The Company does not consider adverse impacts of investment decisions on sustainability factors.  This has been determined because the Company does not deem sustainability factors to be of high importance in meeting the investment objectives of its clients.  Furthermore, targeting investments which meet sustainability factors would be difficult, time consuming and costly, given the boutique size and nature of the Company and consequently limited analytical resources in this regard, which may result in detrimental performance to its clients.  Integra’s clients generally do not require and/or request the integration of sustainability considerations into their portfolios and express no sustainability preferences during discussions. 

Article 5: Remuneration Policies

The Company does not integrate sustainability risks in its remuneration policy, for the reasons described in the disclosures above.

Exceptions - Integra allows all its clients the ability to express their preferences in respect of the integration of adverse sustainability impacts and/or sustainability risks generally, as part of the onboarding process.  Where a client expresses an interest in integrating such sustainability considerations, this is implemented by the Company as part of its services to that specific client.

Version Control
V1 - Initial Disclosure: 01-Jan-2023
V2 - General Updates: 08-Jan-2026