Our policy
Metatron Capital SICAV plc (“Company”) has licence no. PIF/177 of the Malta Financial Services Authority (“MFSA”) as a multi-fund investment company with variable basic capital (SICAV), which was established pursuant to the Act Cap 386 of the Collection of Laws of Malta with the registration number SV177 and is allowed to form separate sub-funds and issue classes of shares of these sub-funds, while each sub-fund operates with separate assets.
The sub-funds (“Funds”) managed by the Company are Professional Investor Funds (“PIFs”), which are intended only for qualified investors in the Czech Republic under the Act on Investment Companies and Investment Funds. For this type of funds regulated by the MFSA it means a minimal degree of oversight. The PIF is not a retail type of fund, therefore the MFSA protection for retail funds does not apply to it.
The fact that the Funds are registered in the list maintained by the Czech National Bank also does not establish protection and oversight as in the case of collective investment funds for retail. The offer of investment in the Funds is not specifically focused on persons from the Slovak Republic and investing in the Funds is not intended for potential investors from the Slovak Republic. For the avoidance of doubt, it applies that the Funds will not be distributed in the Slovak Republic, the offer of investing in the Funds does not constitute a public offer of securities implemented under Slovak legislation and the Slovak Republic is not among the states to which is the offer of investment in the Funds directed. In the event of failure of the Company, the investors shall not be protected by any agreement on compensation or guarantee scheme, i.e. the Securities Traders Guarantee Fund or the Deposit Insurance Fund, or a similar foreign system shall not apply to them.
Unless otherwise indicated, the information and services provided on these web pages have been published by the Company and have a purely non-binding and informative character. The information provided is for information only and should not be regarded as a recommendation or as an investment advice. The types of mentioned investment instruments are intended only for qualified investors and decisions based on the information provided by the Company are at own risk of the investor.
These web pages are for informational purposes only and do not constitute any offer to conclude a contract related to the above mentioned financial instrument or investment service. They are not a basis for conclusion of any contract or arrangement of obligation of any kind. They may not be referenced in connection with conclusion of any contract or arrangement of any kind of obligation. Information and services provided on these web pages do not constitute an offer to use such information and services in jurisdictions where it is prohibited by law or regulation. None of the information constitutes investment, legal, tax or other advice. The Company shall not be responsible for the accuracy of the information contained on the Company’s web pages and shall not be liable for any loss arising from any use of this information. In case of any discrepancy between the language versions of this disclaimer the English version shall be decisive.
Potential investors are advised to carefully read the relevant legal documents and consult any potential investments with their tax, financial and legal counsellors before making investment decisions.
An investment into the Funds may have a speculative character and it may involve a high degree of risk. The possibility of withdrawal of resources from the Funds may be limited and investors may not have access to capital at a time of need. The portfolio is fully under trade control of portfolio managers, who may use leverage, which may cause volatility of investment. Investors should not make investments in the Funds of the Company, unless they are prepared to lose a significant part of them.
Fees attached to the investment may be higher than in other alternative investments, therefore the investors may lose part of their profits. There is no guarantee that the investment objectives will be achieved. Furthermore, the existing results cannot be interpreted as an indicator of future performance.
All provided information shall be confidential. Information may not be reproduced, distributed or published in full or partial form for any purpose, and may not be provided to any third party for any purpose without prior consent of the directors of the Company. This information has been prepared without regard to specific investment objectives, financial situation, or particular needs of a specific investor.
The company falls within scope of Regulation (EU) 2019/2088 of the European Parliament of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (the Sustainable Finance Disclosure Regulation or SFDR), which will come into force on the 10th March, 2021 requiring financial market participants, including the Company, to make certain sustainability-related disclosures to end investors.
No consideration of sustainability adverse impacts
The Company currently has three sub-funds (the “Funds”). Presently, when making investment decisions the Company does not consider the adverse impacts of its investment decisions on sustainability factors in terms of the SFDR as this is not relevant to: (1) the composition of the Funds’ portfolios; and (2) the investment strategies and/or policies of its Funds. The Company may possibly consider such adverse impacts in respect of future mandates in line with its Sustainability Risk Policy (further details of which are set out below).
Sustainability Risk Policy
In line with the requirements imposed on in-scope financial market participants, the Company has formulated its Sustainability Risk Policy outlining the approach that the Company will take to integrating ESG considerations into its investment management processes by assessing not only all relevant financial risks but also relevant sustainability risks, with a view to mitigating risks and enhancing returns over the medium to long-term.
Although the Company does not currently integrate sustainability risks in its investment decision making processes, the Company will, in respect of other fund/s which may be onboarded in future, incorporate ESG considerations and make an assessment of sustainability risks to the extent relevant to: (i) the nature of the fund/s; and (ii) appetite of investors subscribing to the fund/s.
To the extent that ESG considerations and, or assessment of sustainability risks are relevant to future mandates, the below approaches may be undertaken.
1) ESG integration
To the extent that sustainability risks are considered relevant to any future Sub-Funds,the Company undertakes to integrate sustainability risks into its investment decision-making processes whilst taking into account the investment strategy and risk profile of the Sub-Funds’ portfolios. The sustainability risks, when applied, may have a material impact on long-term returns for investors. Please refer to the section entitled ‘Risk Factors’ in this respect.
The Company has opted not to comply with the Principal Adverse Impacts (PAI) regime established under the SFDR, both generally under Article 4 of the SFDR, and more specifically in relation to the Sub-Funds under Article 7 of the SFDR. While the Company is supportive of the policy aims of the PAI regime to improve transparency to clients, the Company is aware that, considering the scale of its activities and the types of products, it would be challenging to comply with the PAI regime of the SFDR. The Company also believes that some of its investment strategies cannot currently support the adoption of the PAI regime, as these strategies involve underlying securities or products where it is impossible to conduct a detailed due diligence on the adverse sustainability impact. Finally, the Company is concerned about the current lack of readily available data to comply with the reporting requirements of the PAI statement as companies and market data providers are not yet ready to make all necessary data available. The Company will at least on an annual basis revisit its decision not to comply with the PAI regime and reserves the right to change its position in the future.
The Sub-Funds classify as Article 6 Funds in terms of the SFDR, meaning that the Sub-Funds do not promote environmental or social characteristics in a way that meets the Article 8 classification for SFDR purposes; and that the Sub-Funds do not have Sustainable Investment as their objective in a way that meets the Article 9 classification for SFDR purposes.
For the purpose of the Taxonomy Regulation, the investments made by the Sub-Funds do not take into account the EU criteria for environmentally sustainable economic activities.
2) Screening
The Company could apply a set of filters for the purpose of determining which companies, sectors or activities are eligible or ineligible to be invested in based on its preferences, values and, or ethics. The Company could implement a mix of positive and negative screens in accordance with ethical inclusion or exclusion criteria. Once invested in, the on-going eligibility of said companies, sectors or activities is likely to be revisited on a periodic basis, or if there are significant changes.
The Sustainability Risk Policy will be reviewed at least once a year to measure success and determine whether it continues to reflect the Company’s investment beliefs.
Remuneration Policy
The Company’s approach to remuneration, as set out in its remuneration policy, does not encourage excessive risk-taking with respect to sustainability risks.
01/12/2023