MiFID (Markets in Financial Instruments Directive) is a European regulation that applies to all E.A.Fs (Financial Advice Companies). Expert Timing System International, E.A.F., S.L. is a registered and supervised E.A.F by the National Stock Market Commission (official registration number: 33).
It is intended to protect retail clients in the security markets. The majority of our clients are not retail ones, but the European Union compels us to inform any visitor of our website about retail client’s rights.
This Directive was adopted to protect such investors. The purpose is to inform retail clients about how much the services of the EAFs cost.
Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on the Disclosure of Sustainable Finance requires the Entity to make certain disclosures on its website, including information on the EAF policies on integration of sustainability risks in its investment decision-making process, its focus on adverse sustainability impacts, and the consistency of its remuneration policies with the integration of sustainability risks.
Its objective is that end investors can have information on the integration of sustainability risks carried out by entities.
In this sense, it should be noted that as part of the investment evaluation, the EAF through its advisory team will consider, if it deems it appropriate, the risks relevant to the sustainability of potential investments.
The Entity tries to recognize, evaluate and adequately weigh all the relevant risk factors when preparing investment recommendations for its clients. Thus, sustainability risks are just one of the various risk aspects considered as part of investment decision making. Other risk factors considered could be (although not exclusively): market, liquidity and counterparty risks. Therefore, ESG (environmental, social and governance) factors and risks are taken into account in the investment decision-making process as an additional tool that provides more information on current and potential non-financial risks of investments. It must therefore be understood in conjunction with the traditional and not exclusive analysis of “sustainable investment”.
While the EAF believes that sustainability risks could have a positive or negative impact on the returns of clients' portfolios; these impacts are not material taking into account the management model followed within the Company.
Due to all of the above, the EAF does not currently have specific sustainability risk policies, or other similar types of ESG policies, for its investments.
In accordance with the provisions of article 4 of the EU Disclosure Regulation, it is reported that currently EXPERT TIMING SYSTEMS INTERNATIONAL, EAF, S.L. (hereinafter “the Entity” does not take into account the adverse effects of investment decisions on sustainability factors (PIAS), as it does not currently have detailed information or due diligence policy in relation to said adverse incidents.
1) Regulation (EU) 2019/2088 of the European Parliament and of the Council, of November 27, 2019, on the disclosure of information related to sustainability in the financial services sector.
The Entity considers that its remuneration policy is consistent with its approach to integrating sustainability risks in the investment decision-making process.
Sustainability risks are taken into account among other potentially relevant risk factors when making investment decisions and failure to take into account any of the relevant risks could have an adverse impact on investment performance.
In general, the Entity's remuneration policy is based on fixed and variable remuneration. Variable remuneration is determined on a discretionary basis and is strongly linked to the results of each employee and the overall financial results of the Entity. With this system, any failure to consider sustainability risks with an adverse impact on investment performance would be reflected in the level of global variable remuneration granted to staff. In addition, in this case, adverse performance is likely to have an impact on variable remuneration at the individual level.
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