Sustainable Finance Disclosure Regulation (“SFDR”)

Gamma Capital Markets Limited (“GCM”) is authorised by the MFSA in terms of the Investment Services Act, 1994 (Cap. 370 of the Laws of Malta) and is required to comply with the licence conditions set out in their licence and the applicable MFSA Rules.

GCM is licenced as an AIFM pursuant to Directive 2011/65/EU and a UCITS Management Company pursuant to Directive 2009/65/EC and provides a number of investment services including investment management and investment advice to professional and retail clients.

With the adoption of the Paris Agreement on climate change and the UN 2030 Agenda for Sustainable Development in 2015, governments from around the world chose a more sustainable path for our planet and our economy. The UN 2030 Agenda has at its core 17 Sustainable Development Goals (SDGs) focused in preparing for a future that ensures stability, a healthy planet, fair, inclusive and resilient societies and prosperous economies. On 8th March 2018, the EC, communicated an Action Plan: Financing Sustainable Growth, to the Financial Industry. SFDR was published on 9th December 2019 clarifying asset managers’ and institutional investors’ duties regarding sustainability.

The financial system has a key role to play in the process. The financial system is being reformed to address the lessons of the financial crisis, and in this context, it can be part of the solution towards a greener and more sustainable economy. Reorienting private capital to more sustainable investments requires a comprehensive shift in how the financial system works and is necessary if the EU is to develop more sustainable economic growth, ensure the stability of the financial system, and foster more transparency and long-termism in the economy.

ESG Integration in The Investment Process

GCM does not make investment decisions based on ESG risks and does not assess Sustainability Factors that may have investment ramifications, and which may have a material impact on the investment’s long-term financial performance. As a result, information on Sustainability Factors does not form part of GCM’s investment decision making or investment recommendation process.

GCM does not carry out an assessment or obtains information on Sustainability Factors in respect of the individual investments in which it invests as the assets managed by the Company are limitedly exposed to ESG Risk.

The Company intends to revise the ESG integration approach described above by 31st May 2025. 

Aligning Compensation with Sustainable Investment Goals

GCM’s Remuneration Policy is aligned with its ESG Policy. Sustainability Factors do not constitute criteria for the assessment of both variable and fixed remuneration of the Company.

Should GCM adopt a different ESG integration approach in their investment process, the ESG Policy, as well as, the Remuneration Policy shall be updated accordingly.