Obligations under the SFDR

As per Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR), the Company is required to disclose sustainability information to help those investors who seek to put their investments into Companies and projects supporting sustainability objectives to make informed choices on the provision of such information.

 

Definitions

A sustainability risk is an environmental, social, or governance (ESG) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.

sustainability factors mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

A Financial Product for the purpose of this Policy shall mean an alternative investment fund (AIF)

Standard Products – Article 6

Products that do not promote ESG characteristics and do not pursue sustainable investments

Light Green Products – Article 8

Products that promote environmental or social characteristics

Dark Green Products – Article 9

Products that have a sustainable investment objective

Classification under the SFDR

Heka Funds SICAV p.l.c. and each of its sub-funds are classified as financial products under Article 6 of the SFDR. Accordingly, sustainability risks are integrated into the investment decision-making process only to the extent that they are considered immaterial to the investment objectives and strategies of the sub-funds.

Consideration of Principal Adverse Impacts (PAIs)

In accordance with Article 7 of SFDR, the Company does not currently consider the principal adverse impacts of investment decisions on sustainability factors at either the Company or sub-fund level. This decision is based on the current lack of reliable and consistent data across the underlying investments, particularly for digital asset-related exposures.

The Board will reassess this position periodically and may opt-in to PAI reporting in the future, should consistent data become available and relevant to the strategies of one or more sub-funds.

Taxonomy Regulation (EU) 2020/852 Disclosure

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Remuneration Policy (Article 5 Disclosure)

Heka Funds SICAV p.l.c. has adopted a Remuneration Policy which is consistent with and promotes sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile, rules or instruments of incorporation of the Company or its sub-funds.

At present, remuneration practices do not include specific integration of sustainability risks, given that these risks are not considered material to the Company’s activities. This position will be reviewed periodically in line with regulatory and operational developments.