Sustainable Finance Disclosure
Based on Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector ("SFDR")
Curmi & Partners Limited (“the Company”) is subject to the requirements of the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 (SFDR) as both a Financial Market Participant and a Financial Advisor. This disclosure is being published in line with the Company’s obligations under Articles 3, 4, and 5 of the SFDR.
Integration of Sustainability Risks
The Company incorporates Environmental, Social and Governance (“ESG”) factors and related sustainability risks as part of its investment decision-making and advisory processes. These are considered alongside other financial and non-financial criteria, including the investment objective, time horizon, and client risk tolerance.
Although ESG considerations form part of the investment analysis, they are not the sole or primary factors driving investment decisions. Instead, they contribute to the broader qualitative assessment of potential investments.
Principal Adverse Impacts (PAIs)
In line with Article 4(1)(b) of the SFDR, the Company does not currently consider the Principal Adverse Impacts (PAIs) of its investment decisions on sustainability factors. The decision not to consider PAIs is due to the Company’s current scale and structure, the challenges of obtaining consistent and reliable ESG data across all asset classes, and the evolving regulatory and market landscape.
At the product level, the Portfolio Manager also elects not to consider PAIs as per SFDR Article 4(1)(a) but instead applies internal ESG policies and controls to address adverse sustainability risks in a practical and proportionate manner.
The Company continues to monitor developments in ESG data availability and regulatory expectations and may revisit this decision in the future.
ESG Screening and Product Scope
The Company does not market specific ESG or green investment products under SFDR Article 8 or 9. However, it applies internal ESG standards across all investment strategies and model portfolios, which include:
Exclusions:
- No investments in companies involved in adult entertainment/pornography or associated with child labour; and
- Conditional exclusion of companies where ≥20% of EBITDA is derived from tobacco or manufacturing/distribution of military weapons.
ESG Quality Screening:
- Portfolios must maintain an average ESG score of BBB or higher, based on MSCI ESG Manager data.
- Maximum of 10% of holdings may be classified as “laggards” (poor ESG performers).
- No more than 30% of holdings may be ESG “unrated” by MSCI.
These ESG considerations are applied during asset selection as part of a broader investment process, without overriding financial considerations.
The Company considers client sustainability preferences as part of its investment advisory services. Where clients express specific concerns or values (e.g., avoiding investments in certain sectors), these are factored into the portfolio construction and product recommendation process on a best-effort basis, within the constraints of available product offerings and data.
Remuneration Policy Alignment with Sustainability Risks
In accordance with SFDR Article 5, the Company’s remuneration policy is structured to avoid encouraging excessive risk-taking with respect to sustainability risks. Performance assessments incorporate both financial and non-financial criteria, including compliance with the Company’s ESG-related guidelines and policies.
Ongoing Review and Future Consideration
The Company remains committed to enhancing its ESG and sustainability risk practices over time. As regulatory guidance and ESG data quality evolve, the Company will continue to assess the potential for incorporating Principal Adverse Impact reporting and increasing its offering of sustainable investment products.
For more information, please click here to download the Company’s ESG Policy.
Updated as at 28th July 2025.