Sustainable Finance Disclosure Regulation (“SFDR”) Disclosures

In accordance with SFDR, Momentum Pensions Malta Limited ("Momentum") as a Retirement Scheme Administrator ("RSA") and Trustee of the Momentum Malta Retirement Trust (“the Scheme”),  is required to provide disclosures on how it considers sustainability risks and the impact of Environmental, Social and Corporate Governance ("ESG").

Definitions

Investment Advisor An entity appointed by the Member and approved by the Retirement Scheme Administrator to provide investment advice to the Member in relation to their individual fund held within the Scheme and who meets the relevant criteria stipulated in Malta Pension Rules relevant to Personal Retirement Schemes;

Investment Manager An entity appointed by the Member and approved by the Retirement Scheme Administrator to carry out the services of managing the investments held in the Trust on behalf of the Member and who meets the relevant criteria stipulated in Malta Pension Rules relevant to Personal Retirement Schemes;

Member An individual accepted by the Trustees as a Member of the Scheme;

Sustainability Risks An environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Principal Adverse Impact (‘PAI’)

The SFDR requires Momentum to disclose on its website whether PAI of investment decisions are considered.

Momentum does not deem relevant the PAI of its investments decisions on sustainability factors in respect of the Scheme and its strategies, in view of the following:

• The Scheme, is a member-directed scheme, meaning that investment decisions are discussed and agreed between the Member and the appointed Investment Advisor or Investment Manager. All directions are to be received by the RSA through the Investment Advisor and signed by the Member, or by the Investment Manager. In this regard, the RSA receives in writing details on the investment portfolio, but the RSA is not responsible for the choice of the underlying investments. In this regard the RSA is not required to assess the PAI of whether the underlying investment promote ESG as its investment objective. In this regard the RSA is not able to assess the PAI of whether the underlying investment promote ESG as its investment objective.
• Investment Guidelines applicable to the Scheme’s Investments, which are accessible to Members and their appointed Investment Advisor/Manager on the Momentum website, which may vary from time to time. The current Investment Guidelines are available here.

Remuneration Policy

The SFDR requires the RSA to include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks and shall publish that information on their websites.

Momentum has a fixed remuneration strategy unless it is justified following a performance assessment based on quantitative and qualitative criteria on the entity and personal level.  In this regard, Momentum views its remuneration structure to be consistent with the integration of sustainability risks.