Sustainable pension plans

Last update: 30/11/2024.

This pension fund (hereinafter, the “Fund”), promotes environmental characteristics, and is classified as an Article 8 of Regulation (EU) 2019/2088 financial product. However, it does not have a sustainable investment objective.

Nevertheless, even though the Fund does not have a sustainable investment objective, it intends to make sustainable investments. The Fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

Within these investments, any potential damage caused must not be significant and must always be mitigated by the greater positive impact generated, in order to not significantly undermine any environmental or social sustainable investment goal, given that the Fund requires all sustainable investments to make a net positive contribution to the sustainable goals being pursued.

Additionally, consideration of the Main Adverse Incidents indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

In order to ensure compliance with the environmental or social characteristics promoted by the Fund, the initial step in the investment strategy involves applying the Fund Manager's exclusion policy, which excludes companies with high exposure to economic activities which have a significantly negative environmental or social impact, or which violate fundamental human or labour rights. The Fund then follows a “best-in-class” investment process.

The management team takes the good governance practices at the companies in which it invests into account, via the indicator used (ASG Rating) for selecting investments. When considering the planned investment ratio for the portfolio, at least 60% of the portfolio's assets is established for investments that promote environmental or social characteristics, and a minimum of 20% of its assets is specified for sustainable investments.

The ESG Rating indicator, which must meet the minimum required value both for each individual asset and at an overall level for the entire portfolio, is used for monitoring the environmental or social characteristics promoted by the Fund.

The fund uses methods which have been specifically developed both for measuring both compliance with environmental or social characteristics, where the “ESG rating” indicator is used as a metric, and for assessing the sustainable investments based on their net positive contribution towards the 17 SDGs.

In order to deploy these methods, the Fund Manager uses data from reputable suppliers. However, there may be constraints on the availability and quality of the non-financial information used for assessing the ESG Rating indicator and sustainable investments. The Fund Manager continuously analyses and monitors the results from these assessments in order mitigate these constraints.

The Fund Manager has a due diligence measure targeting the Fund's underlying assets, which involves continuously monitoring them and their compliance with the environmental and social characteristics promoted by the Fund.

The Fund Manager also has an Engagement Policy which contains processes focussing on active dialogue with issuers (“engagement”) and on voting on potential companies in which to invest.

No specific benchmark index has been identified for establishing the Fund's environmental and social characteristics.

Last update: 30/11/2024.

This financial product promotes environmental or social characteristics, but does not aim at sustainable investment.

However, the fund plans to make sustainable investments. The fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. There are 17 SDGs, including the following: 1) no poverty; 2) end hunger; 3) ensure health and well-being; 4) guarantee education; 5) achieve gender equality, 6) guarantee the availability and sustainable management of water; 7) guarantee access to affordable and sustainable energy; 8) promote economic growth and decent employment; 9) promote industry, innovation and infrastructure; 10) reduce inequalities; 11) achieve inclusive, safe and sustainable cities and communities; 12) guarantee sustainable consumption and production patterns; 13) take measures to combat climate change and its effects; 14) conserve and sustainably use the oceans, seas and marine resources; 15) sustainably manage forests, combat desertification and land degradation; 16) promote justice and peace through institutions and 17) contribute to the Global Partnership for Sustainable Development.

By making this type of sustainable investment, the fund aims to make a positive contribution to the SDGs. To identify these investments, the fund uses an indicator from an external provider, specialised in ESG analysis, with a methodology used to measure the contribution of companies to each of the 17 SDGs, based on their operations, products, services, policies and practices implemented to address these challenges. Based on the above, each company analysed has a positive or negative metric for each of the 17 goals. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

To the extent that the fund requires that any sustainable investment make a net positive contribution to the sustainable goals, this means that the potential damage generated will not be significant, and will always be mitigated by the greater positive impact generated.

In addition to presenting a positive net contribution to the 17 SDGs, the fund's sustainable investments will comply with the principle of Do No Significant Harm to another sustainability goal, which will be achieved through the combination of the following management actions:

1. The very requirement of a positive net contribution to the 17 SDGs, which implies that the potential damage generated to one or several SDGs will not be significant and will always be mitigated by the greater positive impact generated to other SDGs.

2. Controversy analysis, as ESG analysis providers refer to those events or situations in which a company's operations or products may have a negative impact in environmental, social or corporate governance terms. For all investments in the fund, the number and seriousness of the controversies detected will be continuously assessed, ensuring that no investment classified as “sustainable investment” may cause significant harm in ESG terms based on such controversies.

3. The requirement of a minimum ESG rating that helps to ensure that the fund's investments meet minimum standards in the management of environmental, social and corporate governance aspects, thereby eliminating the lowest-performing companies in the management of these factors and that, consequently, can cause significant damage to them.

4. The individual analysis of the quality of corporate governance of the investments made and the requirement that adequate standards are met in terms of ownership structure, management and control bodies, human resources management, accounting and fiscal transparency, as well as business ethics. These characteristics are assessed and scored within the breakdown of the ESG rating, and make it possible to set up an additional filter to ensure that the fund's intended sustainable investments comply with good governance practices.

5. The consideration of the Principal Adverse Impacts (PAIs) on sustainability factors.

6. The application of the Manager's exclusion policy, as detailed below, excludes any companies with significant exposure to economic activities with a highly negative impact in environmental or social terms.

Consideration of the Principal Adverse Impact indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

The management team will take account of the indicators listed in Table 1 and any of those listed in Tables 2 and 3 of Annex I to Delegated Regulation (EU) 2022/1288. The Do No Significant Harm principle is introduced into the investment classification process as “sustainable investments” or as “investments with other environmental or social characteristics”. The assessment of the Do No Significant Harm principle is part of the three pillars underpinning compliance with the regulatory definition of “sustainable investment”.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

Last update: 31/05/2023.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

Last update: 31/05/2023.

Initially, the Manager's exclusion policy is applied, ruling out companies with significant exposure to economic activities with a highly negative environmental or social impact. These activities include the production of weapons of mass destruction, the production of weapons considered controversial due to their impact on the civilian population, the generation of electricity from highly polluting sources or the exploration and production of oil and gas in areas or using techniques with a high ecological impact. Also excluded are any companies about which there is evidence that they do not respect the fundamental human rights defined by the United Nations or that do not comply with labour rights as defined in the Conventions of the International Labour Organization.

The fund then follows a “best-in-class” investment process, which consists of selecting companies with the best assessment in terms of sustainability according to the aforementioned indicator. At least 60% of the portfolio's assets will have a rating equal to or higher than the minimum set out in the “Monitoring the environmental or social characteristics” section and, within this majority share of the portfolio, sustainable investments must make a positive net contribution to the 17 SDGs set out above, which will account for at least 20% of the Fund's assets.

In addition to the ex-ante assessment, prior to the investment decision, the management team performs a continuous assessment of the portfolio to analyse its alignment with the promoted sustainable characteristics.

The management team considers the good governance practices at the invested companies, via the indicator used (ESG Rating) for selecting investments. Specifically, when assessing the good governance of companies, ESG ratings include a specific section where aspects related to business ethics and the quality of corporate governance are taken into account. Here, various issues are assessed, such as the characteristics of the company's ownership structure, the operating characteristics and the composition of the control bodies, remuneration policies, accounting and fiscal transparency, the existence of control policies and mechanisms that effectively prevent actions in breach of business ethics as well as the existence of disputes related, for example, to cases of bribery, corruption, fraud, money laundering or anti-competitive practices.

Last update: 31/05/2023.

Investments that promote sustainable characteristics will make up at least 60% of the assets in the portfolio. These investments will materialise in at least 20% of the fund's assets in sustainable investments with a social and/or environmental aim, in accordance with the definition of the applicable Regulation (EU) 2019/88.

The fund does not use derivatives to achieve the environmental or social characteristics pursued.

Last update: 31/05/2023.

With a view to implementing the investment strategy and achieving the intended environmental and social characteristics, the management team has set the following requirements:

• All investments considered have a minimum ESG Rating of “BBB” on a scale ranging from AAA to CCC, with AAA being the best and CCC being the worst, or equivalent depending on the scale of the chosen ESG analytics provider(s).
• The portfolio has, in aggregate and on average, a minimum ESG Rating of “A” or equivalent depending on the scale of the chosen ESG analysis provider(s).

Any individual investment that does not reach the minimum required rating cannot be considered as adequately promoting the environmental and social characteristics and will no longer be included in the section on “Investments adjusted for environmental or social characteristics”. In order to assess the permanence of these investments, the team will consider the compliance with the portfolio's joint minimum rating target and the minimum proportion of 60% of the equity assigned to assets of “Investments adjusted for environmental or social characteristics”.

One of the fund's indicators is the appropriate compliance with the environmental and social characteristics pursued by the “ESG rating” for the companies it invests in.

Last update: 31/05/2023.

The “ESG rating” used as an indicator is a metric prepared by independent companies, specialised in the analysis of extra-financial risks. It offers a global assessment of the previously described environmental and social characteristics. However, the calculation methodology of an “ESG rating” differs depending on the provider. In general, all of them are based on identifying the most relevant environmental, social and governance variables, assessing and weighing them based on their relevance according to the sector or sub-industry to which the analysed company belongs. The final assessment is expressed in the form of a joint rating, although there is also the possibility of accessing individual scores for environmental, social and governance practices. The “ESG rating” is usually expressed in the form of letters or numbers depending on the provider, but in both cases, the values are expressed using a level scale to identify the degree of exposure to extra-financial risks faced by the analysed company, and its ability to manage them. Based on this scale, it is possible to determine if an investment has environmental, social and governance characteristics associated with a very low, low, medium, high or very high sustainability risk, and promote the selection of those that best fit the fund's goals.

With regard to Public Fixed Income, in addition to the “ESG rating” of the issuing companies, there are labels (green, social, sustainable) associated with specific emissions that contribute to and reinforce the identification of the investment's environmental or social characteristics.

The asset management vehicle arranged only uses external providers to determine ESG ratings and therefore does not develop its own methodology for these ratings.

As regards the methodology to assess the characteristics required of “sustainable investments”, and taking into account that their regulatory definition states that:
(1) the investment must be made in an economic activity that contributes to an environmental or social goal;
(2) the investment must not significantly harm any environmental or social goal (assessed based on the DNSH principle through the aforementioned indicators) and
(3) the investee company must follow good governance practices.

The asset management vehicle arranged implements its classification methodology based on the control and monitoring of:
(1) the net contribution to the Sustainable Development Goals as outlined in the relevant section.
(2) the favourable or unfavourable comparison in relative terms of the most significant metrics listed in Table 1 of Appendix I to Delegated Regulation (EU) 2022/1288, such as the intensity of greenhouse gas emissions, violations of the principles of the United Nations Global Compact, the lack of compliance processes and mechanisms to track compliance with these principles, the gender diversity of the board of directors or exposure to controversial weapons, and
(3) a check through the ESG rating and the analysis of controversies that good governance practices are properly followed.

The investment process takes account of these two methodologies, and the Manager monitors their compliance on a monthly basis. Additionally, an annual report is released on the degree of achievement of the investment strategy and the social or environmental characteristics promoted by the fund.

Last update: 30/11/2024.

MSCI ESG Research, a reputable third-party provider, provides non-financial data for the underlying assets in which the plan invests to assess whether the characteristics promoted by the plan have been attained and to assess these underlying assets using the aforementioned “ESG ratings”. Non-financial data cover all data concerning environmental, social and corporate governance issues and, as a result, also include data concerning “principal adverse impacts”.

As a result, the quality of these data hinges upon the provider chosen and whether these data are published by companies or issuers. When specific data are not published by companies or issuers, estimates may be required that may be significantly different from the figures ultimately published. The asset management vehicle arranged does not produce its own estimates and instead uses estimates from its external providers. In order to ensure that the data are high quality, the asset management vehicle arranged uses reputable external providers, monitoring and comparing how available and up-to-date the data provided by each of them are.

For indirect investments through CISs classified as Article 8 or 9 of Regulation (EU) 2019/88 products, data provided by their respective management companies are used.

The proportion of estimated data used from the providers, as well as from the management companies relating to investments in CISs is a tricky parameter to establish with the information currently available.

Last update: 31/05/2023.

The methods used, and which have been described above, may present limitations and consequently may require modifications over time. The right measurement of how the social or environmental characteristics promoted by the fund are met may be limited by the availability and quality of the extra-financial information used to assess the ESG characteristics of the underlying assets in which it invests and/or of the asset issuers. The classification of assets as “sustainable investments” also requires a significant volume of data and assessment criteria that are not agreed upon at the European level, which can make the comparison between plans from different financial institutions complex.

In order for these limitations not to affect how the environmental or social characteristics promoted by the fund are met, the Manager constantly analyses and monitors the results achieved and establishes periodic checks on the percentage of assets that meet said characteristics, as well as the percentage of sustainable investments, confirming that both percentages meet the established thresholds.

Last update: 31/05/2023.

Regarding the due diligence measures for the fund's underlying assets, the Manager has established an ex-ante control that does not allow the trading of an asset if this means that the fund does not meet the thresholds established in section “Monitoring environmental or social characteristics".

Also, a periodic ex-post control is carried out, considering sudden drops in the ESG rating of the financial assets that make up the fund's portfolio.

And the information provided by external providers is periodically updated to improve the coverage of the underlying assets that the fund invests in.

Last update: 31/05/2023.

The Management Company will monitor certain aspects of the business strategies, performance and financial and non-financial risk, capital structure, social and environmental impact and corporate governance of specific companies, to the extent it deems appropriate considering its investment strategy and the nature and size of its investment in them.

To perform this monitoring work, the Management Company may use various sources and mechanisms, e.g. the review of non-financial information, particularly as regards ESG Risks and Factors.

The Management Company interprets its fiduciary duty with respect to the unit holders of the Managed Vehicles as an effort to maximise the value of their investments in both the long and short term, in compliance with its management and administration responsibilities, not only as a shareholder but also by actively participating with the company's management.

The Management Company is aware that, through participation in the Annual General Meetings or in engagement with the companies,“” faster growth and higher profitability are possible in the long run. The Management Company believes it is possible to improve long-term profitability and generate a positive impact on sustainability by integrating sustainability risks and factors into its Managed Vehicles and the investee companies.

Last update: 31/05/2023.

No specific benchmark index has been identified for establishing the plan's environmental and social characteristics.

Statement on the Main Adverse Impacts of Investment Decisions on Sustainability Factors 30 June 2023.

Statement of the Main Adverse Impacts of Investment Advice on Sustainability Factors 30 June 2023.

Statement of Principal Adverse Impacts of investment advice on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2026.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2026.

Last update: 30/11/2024.

This pension fund (hereinafter, the “Fund”), promotes environmental characteristics, and is classified as an Article 8 of Regulation (EU) 2019/2088 financial product. However, it does not have a sustainable investment objective.

Nevertheless, even though the Fund does not have a sustainable investment objective, it intends to make sustainable investments. The Fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

Within these investments, any potential damage caused must not be significant and must always be mitigated by the greater positive impact generated, in order to not significantly undermine any environmental or social sustainable investment goal, given that the Fund requires all sustainable investments to make a net positive contribution to the sustainable goals being pursued.

Additionally, consideration of the Main Adverse Incidents indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

In order to ensure compliance with the environmental or social characteristics promoted by the Fund, the initial step in the investment strategy involves applying the Fund Manager's exclusion policy, which excludes companies with high exposure to economic activities which have a significantly negative environmental or social impact, or which violate fundamental human or labour rights. The Fund then follows a “best-in-class” investment process.

The management team takes the good governance practices at the companies in which it invests into account, via the indicator used (ASG Rating) for selecting investments. When considering the planned investment ratio for the portfolio, at least 60% of the portfolio's assets is established for investments that promote environmental or social characteristics, and a minimum of 20% of its assets is specified for sustainable investments.

The ESG Rating indicator, which must meet the minimum required value both for each individual asset and at an overall level for the entire portfolio, is used for monitoring the environmental or social characteristics promoted by the Fund.

The fund uses methods which have been specifically developed both for measuring both compliance with environmental or social characteristics, where the “ESG rating” indicator is used as a metric, and for assessing the sustainable investments based on their net positive contribution towards the 17 SDGs.

In order to deploy these methods, the Fund Manager uses data from reputable suppliers. However, there may be constraints on the availability and quality of the non-financial information used for assessing the ESG Rating indicator and sustainable investments. The Fund Manager continuously analyses and monitors the results from these assessments in order mitigate these constraints.

The Fund Manager has a due diligence measure targeting the Fund's underlying assets, which involves continuously monitoring them and their compliance with the environmental and social characteristics promoted by the Fund.

The Fund Manager also has an Engagement Policy which contains processes focussing on active dialogue with issuers (“engagement”) and on voting on potential companies in which to invest.

No specific benchmark index has been identified for establishing the Fund's environmental and social characteristics.

Last update: 30/11/2024.

This financial product promotes environmental or social characteristics, but does not aim at sustainable investment.

However, the fund plans to make sustainable investments. The fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. There are 17 SDGs, including the following: 1) no poverty; 2) end hunger; 3) ensure health and well-being; 4) guarantee education; 5) achieve gender equality, 6) guarantee the availability and sustainable management of water; 7) guarantee access to affordable and sustainable energy; 8) promote economic growth and decent employment; 9) promote industry, innovation and infrastructure; 10) reduce inequalities; 11) achieve inclusive, safe and sustainable cities and communities; 12) guarantee sustainable consumption and production patterns; 13) take measures to combat climate change and its effects; 14) conserve and sustainably use the oceans, seas and marine resources; 15) sustainably manage forests, combat desertification and land degradation; 16) promote justice and peace through institutions and 17) contribute to the Global Partnership for Sustainable Development.

By making this type of sustainable investment, the fund aims to make a positive contribution to the SDGs. To identify these investments, the fund uses an indicator from an external provider, specialised in ESG analysis, with a methodology used to measure the contribution of companies to each of the 17 SDGs, based on their operations, products, services, policies and practices implemented to address these challenges. Based on the above, each company analysed has a positive or negative metric for each of the 17 goals. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

To the extent that the fund requires that any sustainable investment make a net positive contribution to the sustainable goals, this means that the potential damage generated will not be significant, and will always be mitigated by the greater positive impact generated.

In addition to presenting a positive net contribution to the 17 SDGs, the fund's sustainable investments will comply with the principle of Do No Significant Harm to another sustainability goal, which will be achieved through the combination of the following management actions:

1. The very requirement of a positive net contribution to the 17 SDGs, which implies that the potential damage generated to one or several SDGs will not be significant and will always be mitigated by the greater positive impact generated to other SDGs.

2. Controversy analysis, as ESG analysis providers refer to those events or situations in which a company's operations or products may have a negative impact in environmental, social or corporate governance terms. For all investments in the fund, the number and seriousness of the controversies detected will be continuously assessed, ensuring that no investment classified as “sustainable investment” may cause significant harm in ESG terms based on such controversies.

3. The requirement of a minimum ESG rating that helps to ensure that the fund's investments meet minimum standards in the management of environmental, social and corporate governance aspects, thereby eliminating the lowest-performing companies in the management of these factors and that, consequently, can cause significant damage to them.

4. The individual analysis of the quality of corporate governance of the investments made and the requirement that adequate standards are met in terms of ownership structure, management and control bodies, human resources management, accounting and fiscal transparency, as well as business ethics. These characteristics are assessed and scored within the breakdown of the ESG rating, and make it possible to set up an additional filter to ensure that the fund's intended sustainable investments comply with good governance practices.

5. The consideration of the Principal Adverse Impacts (PAIs) on sustainability factors.

6. The application of the Manager's exclusion policy, as detailed below, excludes any companies with significant exposure to economic activities with a highly negative impact in environmental or social terms.

Consideration of the Principal Adverse Impact indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

The management team will take account of the indicators listed in Table 1 and any of those listed in Tables 2 and 3 of Annex I to Delegated Regulation (EU) 2022/1288. The Do No Significant Harm principle is introduced into the investment classification process as “sustainable investments” or as “investments with other environmental or social characteristics”. The assessment of the Do No Significant Harm principle is part of the three pillars underpinning compliance with the regulatory definition of “sustainable investment”.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

Last update: 31/05/2023.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

Last update: 31/05/2023.

Initially, the Manager's exclusion policy is applied, ruling out companies with significant exposure to economic activities with a highly negative environmental or social impact. These activities include the production of weapons of mass destruction, the production of weapons considered controversial due to their impact on the civilian population, the generation of electricity from highly polluting sources or the exploration and production of oil and gas in areas or using techniques with a high ecological impact. Also excluded are any companies about which there is evidence that they do not respect the fundamental human rights defined by the United Nations or that do not comply with labour rights as defined in the Conventions of the International Labour Organization.

The fund then follows a “best-in-class” investment process, which consists of selecting companies with the best assessment in terms of sustainability according to the aforementioned indicator. At least 60% of the portfolio's assets will have a rating equal to or higher than the minimum set out in the “Monitoring the environmental or social characteristics” section and, within this majority share of the portfolio, sustainable investments must make a positive net contribution to the 17 SDGs set out above, which will account for at least 20% of the Fund's assets.

In addition to the ex-ante assessment, prior to the investment decision, the management team performs a continuous assessment of the portfolio to analyse its alignment with the promoted sustainable characteristics.

The management team considers the good governance practices at the invested companies, via the indicator used (ESG Rating) for selecting investments. Specifically, when assessing the good governance of companies, ESG ratings include a specific section where aspects related to business ethics and the quality of corporate governance are taken into account. Here, various issues are assessed, such as the characteristics of the company's ownership structure, the operating characteristics and the composition of the control bodies, remuneration policies, accounting and fiscal transparency, the existence of control policies and mechanisms that effectively prevent actions in breach of business ethics as well as the existence of disputes related, for example, to cases of bribery, corruption, fraud, money laundering or anti-competitive practices.

Last update: 31/05/2023.

Investments that promote sustainable characteristics will make up at least 60% of the assets in the portfolio. These investments will materialise in at least 20% of the fund's assets in sustainable investments with a social and/or environmental aim, in accordance with the definition of the applicable Regulation (EU) 2019/88.

The fund does not use derivatives to achieve the environmental or social characteristics pursued.

Last update: 31/05/2023.

With a view to implementing the investment strategy and achieving the intended environmental and social characteristics, the management team has set the following requirements:

• All investments considered have a minimum ESG Rating of “BBB” on a scale ranging from AAA to CCC, with AAA being the best and CCC being the worst, or equivalent depending on the scale of the chosen ESG analytics provider(s).
• The portfolio has, in aggregate and on average, a minimum ESG Rating of “A” or equivalent depending on the scale of the chosen ESG analysis provider(s).

Any individual investment that does not reach the minimum required rating cannot be considered as adequately promoting the environmental and social characteristics and will no longer be included in the section on “Investments adjusted for environmental or social characteristics”. In order to assess the permanence of these investments, the team will consider the compliance with the portfolio's joint minimum rating target and the minimum proportion of 60% of the equity assigned to assets of “Investments adjusted for environmental or social characteristics”.

One of the fund's indicators is the appropriate compliance with the environmental and social characteristics pursued by the “ESG rating” for the companies it invests in.

Last update: 31/05/2023.

The “ESG rating” used as an indicator is a metric prepared by independent companies, specialised in the analysis of extra-financial risks. It offers a global assessment of the previously described environmental and social characteristics. However, the calculation methodology of an “ESG rating” differs depending on the provider. In general, all of them are based on identifying the most relevant environmental, social and governance variables, assessing and weighing them based on their relevance according to the sector or sub-industry to which the analysed company belongs. The final assessment is expressed in the form of a joint rating, although there is also the possibility of accessing individual scores for environmental, social and governance practices. The “ESG rating” is usually expressed in the form of letters or numbers depending on the provider, but in both cases, the values are expressed using a level scale to identify the degree of exposure to extra-financial risks faced by the analysed company, and its ability to manage them. Based on this scale, it is possible to determine if an investment has environmental, social and governance characteristics associated with a very low, low, medium, high or very high sustainability risk, and promote the selection of those that best fit the fund's goals.

With regard to Public Fixed Income, in addition to the “ESG rating” of the issuing companies, there are labels (green, social, sustainable) associated with specific emissions that contribute to and reinforce the identification of the investment's environmental or social characteristics.

The asset management vehicle arranged only uses external providers to determine ESG ratings and therefore does not develop its own methodology for these ratings.

As regards the methodology to assess the characteristics required of “sustainable investments”, and taking into account that their regulatory definition states that:
(1) the investment must be made in an economic activity that contributes to an environmental or social goal;
(2) the investment must not significantly harm any environmental or social goal (assessed based on the DNSH principle through the aforementioned indicators) and
(3) the investee company must follow good governance practices.

The asset management vehicle arranged implements its classification methodology based on the control and monitoring of:
(1) the net contribution to the Sustainable Development Goals as outlined in the relevant section.
(2) the favourable or unfavourable comparison in relative terms of the most significant metrics listed in Table 1 of Appendix I to Delegated Regulation (EU) 2022/1288, such as the intensity of greenhouse gas emissions, violations of the principles of the United Nations Global Compact, the lack of compliance processes and mechanisms to track compliance with these principles, the gender diversity of the board of directors or exposure to controversial weapons, and
(3) a check through the ESG rating and the analysis of controversies that good governance practices are properly followed.

The investment process takes account of these two methodologies, and the Manager monitors their compliance on a monthly basis. Additionally, an annual report is released on the degree of achievement of the investment strategy and the social or environmental characteristics promoted by the fund.

Last update: 30/11/2024.

MSCI ESG Research, a reputable third-party provider, provides non-financial data for the underlying assets in which the plan invests to assess whether the characteristics promoted by the plan have been attained and to assess these underlying assets using the aforementioned “ESG ratings”. Non-financial data cover all data concerning environmental, social and corporate governance issues and, as a result, also include data concerning “principal adverse impacts”.

As a result, the quality of these data hinges upon the provider chosen and whether these data are published by companies or issuers. When specific data are not published by companies or issuers, estimates may be required that may be significantly different from the figures ultimately published. The asset management vehicle arranged does not produce its own estimates and instead uses estimates from its external providers. In order to ensure that the data are high quality, the asset management vehicle arranged uses reputable external providers, monitoring and comparing how available and up-to-date the data provided by each of them are.

For indirect investments through CISs classified as Article 8 or 9 of Regulation (EU) 2019/88 products, data provided by their respective management companies are used.

The proportion of estimated data used from the providers, as well as from the management companies relating to investments in CISs is a tricky parameter to establish with the information currently available.

Last update: 31/05/2023.

The methods used, and which have been described above, may present limitations and consequently may require modifications over time. The right measurement of how the social or environmental characteristics promoted by the fund are met may be limited by the availability and quality of the extra-financial information used to assess the ESG characteristics of the underlying assets in which it invests and/or of the asset issuers. The classification of assets as “sustainable investments” also requires a significant volume of data and assessment criteria that are not agreed upon at the European level, which can make the comparison between plans from different financial institutions complex.

In order for these limitations not to affect how the environmental or social characteristics promoted by the fund are met, the Manager constantly analyses and monitors the results achieved and establishes periodic checks on the percentage of assets that meet said characteristics, as well as the percentage of sustainable investments, confirming that both percentages meet the established thresholds.

Last update: 31/05/2023.

Regarding the due diligence measures for the fund's underlying assets, the Manager has established an ex-ante control that does not allow the trading of an asset if this means that the fund does not meet the thresholds established in section “Monitoring environmental or social characteristics".

Also, a periodic ex-post control is carried out, considering sudden drops in the ESG rating of the financial assets that make up the fund's portfolio.

And the information provided by external providers is periodically updated to improve the coverage of the underlying assets that the fund invests in.

Last update: 31/05/2023.

The Management Company will monitor certain aspects of the business strategies, performance and financial and non-financial risk, capital structure, social and environmental impact and corporate governance of specific companies, to the extent it deems appropriate considering its investment strategy and the nature and size of its investment in them.

To perform this monitoring work, the Management Company may use various sources and mechanisms, e.g. the review of non-financial information, particularly as regards ESG Risks and Factors.

The Management Company interprets its fiduciary duty with respect to the unit holders of the Managed Vehicles as an effort to maximise the value of their investments in both the long and short term, in compliance with its management and administration responsibilities, not only as a shareholder but also by actively participating with the company's management.

The Management Company is aware that, through participation in the Annual General Meetings or in engagement with the companies,“” faster growth and higher profitability are possible in the long run. The Management Company believes it is possible to improve long-term profitability and generate a positive impact on sustainability by integrating sustainability risks and factors into its Managed Vehicles and the investee companies.

Last update: 31/05/2023.

No specific benchmark index has been identified for establishing the plan's environmental and social characteristics.

Statement on the Main Adverse Impacts of Investment Decisions on Sustainability Factors 30 June 2023.

Statement of the Main Adverse Impacts of Investment Advice on Sustainability Factors 30 June 2023.

Statement of Principal Adverse Impacts of investment advice on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2026.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2026.

Last update: 30/11/2024.

This pension fund (hereinafter, the “Fund”), promotes environmental characteristics, and is classified as an Article 8 of Regulation (EU) 2019/2088 financial product. However, it does not have a sustainable investment objective.

Nevertheless, even though the Fund does not have a sustainable investment objective, it intends to make sustainable investments. The Fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

Within these investments, any potential damage caused must not be significant and must always be mitigated by the greater positive impact generated, in order to not significantly undermine any environmental or social sustainable investment goal, given that the Fund requires all sustainable investments to make a net positive contribution to the sustainable goals being pursued.

Additionally, consideration of the Main Adverse Incidents indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

In order to ensure compliance with the environmental or social characteristics promoted by the Fund, the initial step in the investment strategy involves applying the Fund Manager's exclusion policy, which excludes companies with high exposure to economic activities which have a significantly negative environmental or social impact, or which violate fundamental human or labour rights. The Fund then follows a “best-in-class” investment process.

The management team takes the good governance practices at the companies in which it invests into account, via the indicator used (ASG Rating) for selecting investments. When considering the planned investment ratio for the portfolio, at least 60% of the portfolio's assets is established for investments that promote environmental or social characteristics, and a minimum of 20% of its assets is specified for sustainable investments.

The ESG Rating indicator, which must meet the minimum required value both for each individual asset and at an overall level for the entire portfolio, is used for monitoring the environmental or social characteristics promoted by the Fund.

The fund uses methods which have been specifically developed both for measuring both compliance with environmental or social characteristics, where the “ESG rating” indicator is used as a metric, and for assessing the sustainable investments based on their net positive contribution towards the 17 SDGs.

In order to deploy these methods, the Fund Manager uses data from reputable suppliers. However, there may be constraints on the availability and quality of the non-financial information used for assessing the ESG Rating indicator and sustainable investments. The Fund Manager continuously analyses and monitors the results from these assessments in order mitigate these constraints.

The Fund Manager has a due diligence measure targeting the Fund's underlying assets, which involves continuously monitoring them and their compliance with the environmental and social characteristics promoted by the Fund.

The Fund Manager also has an Engagement Policy which contains processes focussing on active dialogue with issuers (“engagement”) and on voting on potential companies in which to invest.

No specific benchmark index has been identified for establishing the Fund's environmental and social characteristics.

Last update: 30/11/2024.

This financial product promotes environmental or social characteristics, but does not aim at sustainable investment.

However, the fund plans to make sustainable investments. The fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. There are 17 SDGs, including the following: 1) no poverty; 2) end hunger; 3) ensure health and well-being; 4) guarantee education; 5) achieve gender equality, 6) guarantee the availability and sustainable management of water; 7) guarantee access to affordable and sustainable energy; 8) promote economic growth and decent employment; 9) promote industry, innovation and infrastructure; 10) reduce inequalities; 11) achieve inclusive, safe and sustainable cities and communities; 12) guarantee sustainable consumption and production patterns; 13) take measures to combat climate change and its effects; 14) conserve and sustainably use the oceans, seas and marine resources; 15) sustainably manage forests, combat desertification and land degradation; 16) promote justice and peace through institutions and 17) contribute to the Global Partnership for Sustainable Development.

By making this type of sustainable investment, the fund aims to make a positive contribution to the SDGs. To identify these investments, the fund uses an indicator from an external provider, specialised in ESG analysis, with a methodology used to measure the contribution of companies to each of the 17 SDGs, based on their operations, products, services, policies and practices implemented to address these challenges. Based on the above, each company analysed has a positive or negative metric for each of the 17 goals. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

To the extent that the fund requires that any sustainable investment make a net positive contribution to the sustainable goals, this means that the potential damage generated will not be significant, and will always be mitigated by the greater positive impact generated.

In addition to presenting a positive net contribution to the 17 SDGs, the fund's sustainable investments will comply with the principle of Do No Significant Harm to another sustainability goal, which will be achieved through the combination of the following management actions:

1. The very requirement of a positive net contribution to the 17 SDGs, which implies that the potential damage generated to one or several SDGs will not be significant and will always be mitigated by the greater positive impact generated to other SDGs.

2. Controversy analysis, as ESG analysis providers refer to those events or situations in which a company's operations or products may have a negative impact in environmental, social or corporate governance terms. For all investments in the fund, the number and seriousness of the controversies detected will be continuously assessed, ensuring that no investment classified as “sustainable investment” may cause significant harm in ESG terms based on such controversies.

3. The requirement of a minimum ESG rating that helps to ensure that the fund's investments meet minimum standards in the management of environmental, social and corporate governance aspects, thereby eliminating the lowest-performing companies in the management of these factors and that, consequently, can cause significant damage to them.

4. The individual analysis of the quality of corporate governance of the investments made and the requirement that adequate standards are met in terms of ownership structure, management and control bodies, human resources management, accounting and fiscal transparency, as well as business ethics. These characteristics are assessed and scored within the breakdown of the ESG rating, and make it possible to set up an additional filter to ensure that the fund's intended sustainable investments comply with good governance practices.

5. The consideration of the Principal Adverse Impacts (PAIs) on sustainability factors.

6. The application of the Manager's exclusion policy, as detailed below, excludes any companies with significant exposure to economic activities with a highly negative impact in environmental or social terms.

Consideration of the Principal Adverse Impact indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

The management team will take account of the indicators listed in Table 1 and any of those listed in Tables 2 and 3 of Annex I to Delegated Regulation (EU) 2022/1288. The Do No Significant Harm principle is introduced into the investment classification process as “sustainable investments” or as “investments with other environmental or social characteristics”. The assessment of the Do No Significant Harm principle is part of the three pillars underpinning compliance with the regulatory definition of “sustainable investment”.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

Last update: 31/05/2023.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

Last update: 31/05/2023.

Initially, the Manager's exclusion policy is applied, ruling out companies with significant exposure to economic activities with a highly negative environmental or social impact. These activities include the production of weapons of mass destruction, the production of weapons considered controversial due to their impact on the civilian population, the generation of electricity from highly polluting sources or the exploration and production of oil and gas in areas or using techniques with a high ecological impact. Also excluded are any companies about which there is evidence that they do not respect the fundamental human rights defined by the United Nations or that do not comply with labour rights as defined in the Conventions of the International Labour Organization.

The fund then follows a “best-in-class” investment process, which consists of selecting companies with the best assessment in terms of sustainability according to the aforementioned indicator. At least 60% of the portfolio's assets will have a rating equal to or higher than the minimum set out in the “Monitoring the environmental or social characteristics” section and, within this majority share of the portfolio, sustainable investments must make a positive net contribution to the 17 SDGs set out above, which will account for at least 20% of the Fund's assets.

In addition to the ex-ante assessment, prior to the investment decision, the management team performs a continuous assessment of the portfolio to analyse its alignment with the promoted sustainable characteristics.

The management team considers the good governance practices at the invested companies, via the indicator used (ESG Rating) for selecting investments. Specifically, when assessing the good governance of companies, ESG ratings include a specific section where aspects related to business ethics and the quality of corporate governance are taken into account. Here, various issues are assessed, such as the characteristics of the company's ownership structure, the operating characteristics and the composition of the control bodies, remuneration policies, accounting and fiscal transparency, the existence of control policies and mechanisms that effectively prevent actions in breach of business ethics as well as the existence of disputes related, for example, to cases of bribery, corruption, fraud, money laundering or anti-competitive practices.

Last update: 31/05/2023.

Investments that promote sustainable characteristics will make up at least 60% of the assets in the portfolio. These investments will materialise in at least 20% of the fund's assets in sustainable investments with a social and/or environmental aim, in accordance with the definition of the applicable Regulation (EU) 2019/88.

The fund does not use derivatives to achieve the environmental or social characteristics pursued.

Last update: 31/05/2023.

With a view to implementing the investment strategy and achieving the intended environmental and social characteristics, the management team has set the following requirements:

• All investments considered have a minimum ESG Rating of “BBB” on a scale ranging from AAA to CCC, with AAA being the best and CCC being the worst, or equivalent depending on the scale of the chosen ESG analytics provider(s).
• The portfolio has, in aggregate and on average, a minimum ESG Rating of “A” or equivalent depending on the scale of the chosen ESG analysis provider(s).

Any individual investment that does not reach the minimum required rating cannot be considered as adequately promoting the environmental and social characteristics and will no longer be included in the section on “Investments adjusted for environmental or social characteristics”. In order to assess the permanence of these investments, the team will consider the compliance with the portfolio's joint minimum rating target and the minimum proportion of 60% of the equity assigned to assets of “Investments adjusted for environmental or social characteristics”.

One of the fund's indicators is the appropriate compliance with the environmental and social characteristics pursued by the “ESG rating” for the companies it invests in.

Last update: 31/05/2023.

The “ESG rating” used as an indicator is a metric prepared by independent companies, specialised in the analysis of extra-financial risks. It offers a global assessment of the previously described environmental and social characteristics. However, the calculation methodology of an “ESG rating” differs depending on the provider. In general, all of them are based on identifying the most relevant environmental, social and governance variables, assessing and weighing them based on their relevance according to the sector or sub-industry to which the analysed company belongs. The final assessment is expressed in the form of a joint rating, although there is also the possibility of accessing individual scores for environmental, social and governance practices. The “ESG rating” is usually expressed in the form of letters or numbers depending on the provider, but in both cases, the values are expressed using a level scale to identify the degree of exposure to extra-financial risks faced by the analysed company, and its ability to manage them. Based on this scale, it is possible to determine if an investment has environmental, social and governance characteristics associated with a very low, low, medium, high or very high sustainability risk, and promote the selection of those that best fit the fund's goals.

With regard to Public Fixed Income, in addition to the “ESG rating” of the issuing companies, there are labels (green, social, sustainable) associated with specific emissions that contribute to and reinforce the identification of the investment's environmental or social characteristics.

The asset management vehicle arranged only uses external providers to determine ESG ratings and therefore does not develop its own methodology for these ratings.

As regards the methodology to assess the characteristics required of “sustainable investments”, and taking into account that their regulatory definition states that:
(1) the investment must be made in an economic activity that contributes to an environmental or social goal;
(2) the investment must not significantly harm any environmental or social goal (assessed based on the DNSH principle through the aforementioned indicators) and
(3) the investee company must follow good governance practices.

The asset management vehicle arranged implements its classification methodology based on the control and monitoring of:
(1) the net contribution to the Sustainable Development Goals as outlined in the relevant section.
(2) the favourable or unfavourable comparison in relative terms of the most significant metrics listed in Table 1 of Appendix I to Delegated Regulation (EU) 2022/1288, such as the intensity of greenhouse gas emissions, violations of the principles of the United Nations Global Compact, the lack of compliance processes and mechanisms to track compliance with these principles, the gender diversity of the board of directors or exposure to controversial weapons, and
(3) a check through the ESG rating and the analysis of controversies that good governance practices are properly followed.

The investment process takes account of these two methodologies, and the Manager monitors their compliance on a monthly basis. Additionally, an annual report is released on the degree of achievement of the investment strategy and the social or environmental characteristics promoted by the fund.

Last update: 30/11/2024.

MSCI ESG Research, a reputable third-party provider, provides non-financial data for the underlying assets in which the plan invests to assess whether the characteristics promoted by the plan have been attained and to assess these underlying assets using the aforementioned “ESG ratings”. Non-financial data cover all data concerning environmental, social and corporate governance issues and, as a result, also include data concerning “principal adverse impacts”.

As a result, the quality of these data hinges upon the provider chosen and whether these data are published by companies or issuers. When specific data are not published by companies or issuers, estimates may be required that may be significantly different from the figures ultimately published. The asset management vehicle arranged does not produce its own estimates and instead uses estimates from its external providers. In order to ensure that the data are high quality, the asset management vehicle arranged uses reputable external providers, monitoring and comparing how available and up-to-date the data provided by each of them are.

For indirect investments through CISs classified as Article 8 or 9 of Regulation (EU) 2019/88 products, data provided by their respective management companies are used.

The proportion of estimated data used from the providers, as well as from the management companies relating to investments in CISs is a tricky parameter to establish with the information currently available.

Last update: 31/05/2023.

The methods used, and which have been described above, may present limitations and consequently may require modifications over time. The right measurement of how the social or environmental characteristics promoted by the fund are met may be limited by the availability and quality of the extra-financial information used to assess the ESG characteristics of the underlying assets in which it invests and/or of the asset issuers. The classification of assets as “sustainable investments” also requires a significant volume of data and assessment criteria that are not agreed upon at the European level, which can make the comparison between plans from different financial institutions complex.

In order for these limitations not to affect how the environmental or social characteristics promoted by the fund are met, the Manager constantly analyses and monitors the results achieved and establishes periodic checks on the percentage of assets that meet said characteristics, as well as the percentage of sustainable investments, confirming that both percentages meet the established thresholds.

Last update: 31/05/2023.

Regarding the due diligence measures for the fund's underlying assets, the Manager has established an ex-ante control that does not allow the trading of an asset if this means that the fund does not meet the thresholds established in section “Monitoring environmental or social characteristics".

Also, a periodic ex-post control is carried out, considering sudden drops in the ESG rating of the financial assets that make up the fund's portfolio.

And the information provided by external providers is periodically updated to improve the coverage of the underlying assets that the fund invests in.

Last update: 31/05/2023.

The Management Company will monitor certain aspects of the business strategies, performance and financial and non-financial risk, capital structure, social and environmental impact and corporate governance of specific companies, to the extent it deems appropriate considering its investment strategy and the nature and size of its investment in them.

To perform this monitoring work, the Management Company may use various sources and mechanisms, e.g. the review of non-financial information, particularly as regards ESG Risks and Factors.

The Management Company interprets its fiduciary duty with respect to the unit holders of the Managed Vehicles as an effort to maximise the value of their investments in both the long and short term, in compliance with its management and administration responsibilities, not only as a shareholder but also by actively participating with the company's management.

The Management Company is aware that, through participation in the Annual General Meetings or in engagement with the companies,“” faster growth and higher profitability are possible in the long run. The Management Company believes it is possible to improve long-term profitability and generate a positive impact on sustainability by integrating sustainability risks and factors into its Managed Vehicles and the investee companies.

Last update: 31/05/2023.

No specific benchmark index has been identified for establishing the plan's environmental and social characteristics.

Statement on the Main Adverse Impacts of Investment Decisions on Sustainability Factors 30 June 2023.

Statement of the Main Adverse Impacts of Investment Advice on Sustainability Factors 30 June 2023.

Statement of Principal Adverse Impacts of investment advice on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2026.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2026.

Last update: 30/11/2024.

This pension fund (hereinafter, the “Fund”), promotes environmental characteristics, and is classified as an Article 8 of Regulation (EU) 2019/2088 financial product. However, it does not have a sustainable investment objective.

Nevertheless, even though the Fund does not have a sustainable investment objective, it intends to make sustainable investments. The Fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

Within these investments, any potential damage caused must not be significant and must always be mitigated by the greater positive impact generated, in order to not significantly undermine any environmental or social sustainable investment goal, given that the Fund requires all sustainable investments to make a net positive contribution to the sustainable goals being pursued.

Additionally, consideration of the Main Adverse Incidents indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

In order to ensure compliance with the environmental or social characteristics promoted by the Fund, the initial step in the investment strategy involves applying the Fund Manager's exclusion policy, which excludes companies with high exposure to economic activities which have a significantly negative environmental or social impact, or which violate fundamental human or labour rights. The Fund then follows a “best-in-class” investment process.

The management team takes the good governance practices at the companies in which it invests into account, via the indicator used (ASG Rating) for selecting investments. When considering the planned investment ratio for the portfolio, at least 60% of the portfolio's assets is established for investments that promote environmental or social characteristics, and a minimum of 20% of its assets is specified for sustainable investments.

The ESG Rating indicator, which must meet the minimum required value both for each individual asset and at an overall level for the entire portfolio, is used for monitoring the environmental or social characteristics promoted by the Fund.

The fund uses methods which have been specifically developed both for measuring both compliance with environmental or social characteristics, where the “ESG rating” indicator is used as a metric, and for assessing the sustainable investments based on their net positive contribution towards the 17 SDGs.

In order to deploy these methods, the Fund Manager uses data from reputable suppliers. However, there may be constraints on the availability and quality of the non-financial information used for assessing the ESG Rating indicator and sustainable investments. The Fund Manager continuously analyses and monitors the results from these assessments in order mitigate these constraints.

The Fund Manager has a due diligence measure targeting the Fund's underlying assets, which involves continuously monitoring them and their compliance with the environmental and social characteristics promoted by the Fund.

The Fund Manager also has an Engagement Policy which contains processes focussing on active dialogue with issuers (“engagement”) and on voting on potential companies in which to invest.

No specific benchmark index has been identified for establishing the Fund's environmental and social characteristics.

Last update: 30/11/2024.

This financial product promotes environmental or social characteristics, but does not aim at sustainable investment.

However, the fund plans to make sustainable investments. The fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. There are 17 SDGs, including the following: 1) no poverty; 2) end hunger; 3) ensure health and well-being; 4) guarantee education; 5) achieve gender equality, 6) guarantee the availability and sustainable management of water; 7) guarantee access to affordable and sustainable energy; 8) promote economic growth and decent employment; 9) promote industry, innovation and infrastructure; 10) reduce inequalities; 11) achieve inclusive, safe and sustainable cities and communities; 12) guarantee sustainable consumption and production patterns; 13) take measures to combat climate change and its effects; 14) conserve and sustainably use the oceans, seas and marine resources; 15) sustainably manage forests, combat desertification and land degradation; 16) promote justice and peace through institutions and 17) contribute to the Global Partnership for Sustainable Development.

By making this type of sustainable investment, the fund aims to make a positive contribution to the SDGs. To identify these investments, the fund uses an indicator from an external provider, specialised in ESG analysis, with a methodology used to measure the contribution of companies to each of the 17 SDGs, based on their operations, products, services, policies and practices implemented to address these challenges. Based on the above, each company analysed has a positive or negative metric for each of the 17 goals. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

To the extent that the fund requires that any sustainable investment make a net positive contribution to the sustainable goals, this means that the potential damage generated will not be significant, and will always be mitigated by the greater positive impact generated.

In addition to presenting a positive net contribution to the 17 SDGs, the fund's sustainable investments will comply with the principle of Do No Significant Harm to another sustainability goal, which will be achieved through the combination of the following management actions:

1. The very requirement of a positive net contribution to the 17 SDGs, which implies that the potential damage generated to one or several SDGs will not be significant and will always be mitigated by the greater positive impact generated to other SDGs.

2. Controversy analysis, as ESG analysis providers refer to those events or situations in which a company's operations or products may have a negative impact in environmental, social or corporate governance terms. For all investments in the fund, the number and seriousness of the controversies detected will be continuously assessed, ensuring that no investment classified as “sustainable investment” may cause significant harm in ESG terms based on such controversies.

3. The requirement of a minimum ESG rating that helps to ensure that the fund's investments meet minimum standards in the management of environmental, social and corporate governance aspects, thereby eliminating the lowest-performing companies in the management of these factors and that, consequently, can cause significant damage to them.

4. The individual analysis of the quality of corporate governance of the investments made and the requirement that adequate standards are met in terms of ownership structure, management and control bodies, human resources management, accounting and fiscal transparency, as well as business ethics. These characteristics are assessed and scored within the breakdown of the ESG rating, and make it possible to set up an additional filter to ensure that the fund's intended sustainable investments comply with good governance practices.

5. The consideration of the Principal Adverse Impacts (PAIs) on sustainability factors.

6. The application of the Manager's exclusion policy, as detailed below, excludes any companies with significant exposure to economic activities with a highly negative impact in environmental or social terms.

Consideration of the Principal Adverse Impact indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

The management team will take account of the indicators listed in Table 1 and any of those listed in Tables 2 and 3 of Annex I to Delegated Regulation (EU) 2022/1288. The Do No Significant Harm principle is introduced into the investment classification process as “sustainable investments” or as “investments with other environmental or social characteristics”. The assessment of the Do No Significant Harm principle is part of the three pillars underpinning compliance with the regulatory definition of “sustainable investment”.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

Last update: 31/05/2023.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

Last update: 31/05/2023.

Initially, the Manager's exclusion policy is applied, ruling out companies with significant exposure to economic activities with a highly negative environmental or social impact. These activities include the production of weapons of mass destruction, the production of weapons considered controversial due to their impact on the civilian population, the generation of electricity from highly polluting sources or the exploration and production of oil and gas in areas or using techniques with a high ecological impact. Also excluded are any companies about which there is evidence that they do not respect the fundamental human rights defined by the United Nations or that do not comply with labour rights as defined in the Conventions of the International Labour Organization.

The fund then follows a “best-in-class” investment process, which consists of selecting companies with the best assessment in terms of sustainability according to the aforementioned indicator. At least 60% of the portfolio's assets will have a rating equal to or higher than the minimum set out in the “Monitoring the environmental or social characteristics” section and, within this majority share of the portfolio, sustainable investments must make a positive net contribution to the 17 SDGs set out above, which will account for at least 20% of the Fund's assets.

In addition to the ex-ante assessment, prior to the investment decision, the management team performs a continuous assessment of the portfolio to analyse its alignment with the promoted sustainable characteristics.

The management team considers the good governance practices at the invested companies, via the indicator used (ESG Rating) for selecting investments. Specifically, when assessing the good governance of companies, ESG ratings include a specific section where aspects related to business ethics and the quality of corporate governance are taken into account. Here, various issues are assessed, such as the characteristics of the company's ownership structure, the operating characteristics and the composition of the control bodies, remuneration policies, accounting and fiscal transparency, the existence of control policies and mechanisms that effectively prevent actions in breach of business ethics as well as the existence of disputes related, for example, to cases of bribery, corruption, fraud, money laundering or anti-competitive practices.

Last update: 31/05/2023.

Investments that promote sustainable characteristics will make up at least 60% of the assets in the portfolio. These investments will materialise in at least 20% of the fund's assets in sustainable investments with a social and/or environmental aim, in accordance with the definition of the applicable Regulation (EU) 2019/88.

The fund does not use derivatives to achieve the environmental or social characteristics pursued.

Last update: 31/05/2023.

With a view to implementing the investment strategy and achieving the intended environmental and social characteristics, the management team has set the following requirements:

• All investments considered have a minimum ESG Rating of “BBB” on a scale ranging from AAA to CCC, with AAA being the best and CCC being the worst, or equivalent depending on the scale of the chosen ESG analytics provider(s).
• The portfolio has, in aggregate and on average, a minimum ESG Rating of “A” or equivalent depending on the scale of the chosen ESG analysis provider(s).

Any individual investment that does not reach the minimum required rating cannot be considered as adequately promoting the environmental and social characteristics and will no longer be included in the section on “Investments adjusted for environmental or social characteristics”. In order to assess the permanence of these investments, the team will consider the compliance with the portfolio's joint minimum rating target and the minimum proportion of 60% of the equity assigned to assets of “Investments adjusted for environmental or social characteristics”.

One of the fund's indicators is the appropriate compliance with the environmental and social characteristics pursued by the “ESG rating” for the companies it invests in.

Last update: 31/05/2023.

The “ESG rating” used as an indicator is a metric prepared by independent companies, specialised in the analysis of extra-financial risks. It offers a global assessment of the previously described environmental and social characteristics. However, the calculation methodology of an “ESG rating” differs depending on the provider. In general, all of them are based on identifying the most relevant environmental, social and governance variables, assessing and weighing them based on their relevance according to the sector or sub-industry to which the analysed company belongs. The final assessment is expressed in the form of a joint rating, although there is also the possibility of accessing individual scores for environmental, social and governance practices. The “ESG rating” is usually expressed in the form of letters or numbers depending on the provider, but in both cases, the values are expressed using a level scale to identify the degree of exposure to extra-financial risks faced by the analysed company, and its ability to manage them. Based on this scale, it is possible to determine if an investment has environmental, social and governance characteristics associated with a very low, low, medium, high or very high sustainability risk, and promote the selection of those that best fit the fund's goals.

With regard to Public Fixed Income, in addition to the “ESG rating” of the issuing companies, there are labels (green, social, sustainable) associated with specific emissions that contribute to and reinforce the identification of the investment's environmental or social characteristics.

The asset management vehicle arranged only uses external providers to determine ESG ratings and therefore does not develop its own methodology for these ratings.

As regards the methodology to assess the characteristics required of “sustainable investments”, and taking into account that their regulatory definition states that:
(1) the investment must be made in an economic activity that contributes to an environmental or social goal;
(2) the investment must not significantly harm any environmental or social goal (assessed based on the DNSH principle through the aforementioned indicators) and
(3) the investee company must follow good governance practices.

The asset management vehicle arranged implements its classification methodology based on the control and monitoring of:
(1) the net contribution to the Sustainable Development Goals as outlined in the relevant section.
(2) the favourable or unfavourable comparison in relative terms of the most significant metrics listed in Table 1 of Appendix I to Delegated Regulation (EU) 2022/1288, such as the intensity of greenhouse gas emissions, violations of the principles of the United Nations Global Compact, the lack of compliance processes and mechanisms to track compliance with these principles, the gender diversity of the board of directors or exposure to controversial weapons, and
(3) a check through the ESG rating and the analysis of controversies that good governance practices are properly followed.

The investment process takes account of these two methodologies, and the Manager monitors their compliance on a monthly basis. Additionally, an annual report is released on the degree of achievement of the investment strategy and the social or environmental characteristics promoted by the fund.

Last update: 30/11/2024.

MSCI ESG Research, a reputable third-party provider, provides non-financial data for the underlying assets in which the plan invests to assess whether the characteristics promoted by the plan have been attained and to assess these underlying assets using the aforementioned “ESG ratings”. Non-financial data cover all data concerning environmental, social and corporate governance issues and, as a result, also include data concerning “principal adverse impacts”.

As a result, the quality of these data hinges upon the provider chosen and whether these data are published by companies or issuers. When specific data are not published by companies or issuers, estimates may be required that may be significantly different from the figures ultimately published. The asset management vehicle arranged does not produce its own estimates and instead uses estimates from its external providers. In order to ensure that the data are high quality, the asset management vehicle arranged uses reputable external providers, monitoring and comparing how available and up-to-date the data provided by each of them are.

For indirect investments through CISs classified as Article 8 or 9 of Regulation (EU) 2019/88 products, data provided by their respective management companies are used.

The proportion of estimated data used from the providers, as well as from the management companies relating to investments in CISs is a tricky parameter to establish with the information currently available.

Last update: 31/05/2023.

The methods used, and which have been described above, may present limitations and consequently may require modifications over time. The right measurement of how the social or environmental characteristics promoted by the fund are met may be limited by the availability and quality of the extra-financial information used to assess the ESG characteristics of the underlying assets in which it invests and/or of the asset issuers. The classification of assets as “sustainable investments” also requires a significant volume of data and assessment criteria that are not agreed upon at the European level, which can make the comparison between plans from different financial institutions complex.

In order for these limitations not to affect how the environmental or social characteristics promoted by the fund are met, the Manager constantly analyses and monitors the results achieved and establishes periodic checks on the percentage of assets that meet said characteristics, as well as the percentage of sustainable investments, confirming that both percentages meet the established thresholds.

Last update: 31/05/2023.

Regarding the due diligence measures for the fund's underlying assets, the Manager has established an ex-ante control that does not allow the trading of an asset if this means that the fund does not meet the thresholds established in section “Monitoring environmental or social characteristics".

Also, a periodic ex-post control is carried out, considering sudden drops in the ESG rating of the financial assets that make up the fund's portfolio.

And the information provided by external providers is periodically updated to improve the coverage of the underlying assets that the fund invests in.

Last update: 31/05/2023.

The Management Company will monitor certain aspects of the business strategies, performance and financial and non-financial risk, capital structure, social and environmental impact and corporate governance of specific companies, to the extent it deems appropriate considering its investment strategy and the nature and size of its investment in them.

To perform this monitoring work, the Management Company may use various sources and mechanisms, e.g. the review of non-financial information, particularly as regards ESG Risks and Factors.

The Management Company interprets its fiduciary duty with respect to the unit holders of the Managed Vehicles as an effort to maximise the value of their investments in both the long and short term, in compliance with its management and administration responsibilities, not only as a shareholder but also by actively participating with the company's management.

The Management Company is aware that, through participation in the Annual General Meetings or in engagement with the companies,“” faster growth and higher profitability are possible in the long run. The Management Company believes it is possible to improve long-term profitability and generate a positive impact on sustainability by integrating sustainability risks and factors into its Managed Vehicles and the investee companies.

Last update: 31/05/2023.

No specific benchmark index has been identified for establishing the plan's environmental and social characteristics.

Statement on the Main Adverse Impacts of Investment Decisions on Sustainability Factors 30 June 2023.

Statement of the Main Adverse Impacts of Investment Advice on Sustainability Factors 30 June 2023.

Statement of Principal Adverse Impacts of investment advice on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2026.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2026.

Last update: 30/11/2024.

This pension fund (hereinafter, the “Fund”), promotes environmental characteristics, and is classified as an Article 8 of Regulation (EU) 2019/2088 financial product. However, it does not have a sustainable investment objective.

Nevertheless, even though the Fund does not have a sustainable investment objective, it intends to make sustainable investments. The Fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

Within these investments, any potential damage caused must not be significant and must always be mitigated by the greater positive impact generated, in order to not significantly undermine any environmental or social sustainable investment goal, given that the Fund requires all sustainable investments to make a net positive contribution to the sustainable goals being pursued.

Additionally, consideration of the Main Adverse Incidents indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

In order to ensure compliance with the environmental or social characteristics promoted by the Fund, the initial step in the investment strategy involves applying the Fund Manager's exclusion policy, which excludes companies with high exposure to economic activities which have a significantly negative environmental or social impact, or which violate fundamental human or labour rights. The Fund then follows a “best-in-class” investment process.

The management team takes the good governance practices at the companies in which it invests into account, via the indicator used (ASG Rating) for selecting investments. When considering the planned investment ratio for the portfolio, at least 60% of the portfolio's assets is established for investments that promote environmental or social characteristics, and a minimum of 20% of its assets is specified for sustainable investments.

The ESG Rating indicator, which must meet the minimum required value both for each individual asset and at an overall level for the entire portfolio, is used for monitoring the environmental or social characteristics promoted by the Fund.

The fund uses methods which have been specifically developed both for measuring both compliance with environmental or social characteristics, where the “ESG rating” indicator is used as a metric, and for assessing the sustainable investments based on their net positive contribution towards the 17 SDGs.

In order to deploy these methods, the Fund Manager uses data from reputable suppliers. However, there may be constraints on the availability and quality of the non-financial information used for assessing the ESG Rating indicator and sustainable investments. The Fund Manager continuously analyses and monitors the results from these assessments in order mitigate these constraints.

The Fund Manager has a due diligence measure targeting the Fund's underlying assets, which involves continuously monitoring them and their compliance with the environmental and social characteristics promoted by the Fund.

The Fund Manager also has an Engagement Policy which contains processes focussing on active dialogue with issuers (“engagement”) and on voting on potential companies in which to invest.

No specific benchmark index has been identified for establishing the Fund's environmental and social characteristics.

Last update: 30/11/2024.

This financial product promotes environmental or social characteristics, but does not aim at sustainable investment.

However, the fund plans to make sustainable investments. The fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. There are 17 SDGs, including the following: 1) no poverty; 2) end hunger; 3) ensure health and well-being; 4) guarantee education; 5) achieve gender equality, 6) guarantee the availability and sustainable management of water; 7) guarantee access to affordable and sustainable energy; 8) promote economic growth and decent employment; 9) promote industry, innovation and infrastructure; 10) reduce inequalities; 11) achieve inclusive, safe and sustainable cities and communities; 12) guarantee sustainable consumption and production patterns; 13) take measures to combat climate change and its effects; 14) conserve and sustainably use the oceans, seas and marine resources; 15) sustainably manage forests, combat desertification and land degradation; 16) promote justice and peace through institutions and 17) contribute to the Global Partnership for Sustainable Development.

By making this type of sustainable investment, the fund aims to make a positive contribution to the SDGs. To identify these investments, the fund uses an indicator from an external provider, specialised in ESG analysis, with a methodology used to measure the contribution of companies to each of the 17 SDGs, based on their operations, products, services, policies and practices implemented to address these challenges. Based on the above, each company analysed has a positive or negative metric for each of the 17 goals. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

To the extent that the fund requires that any sustainable investment make a net positive contribution to the sustainable goals, this means that the potential damage generated will not be significant, and will always be mitigated by the greater positive impact generated.

In addition to presenting a positive net contribution to the 17 SDGs, the fund's sustainable investments will comply with the principle of Do No Significant Harm to another sustainability goal, which will be achieved through the combination of the following management actions:

1. The very requirement of a positive net contribution to the 17 SDGs, which implies that the potential damage generated to one or several SDGs will not be significant and will always be mitigated by the greater positive impact generated to other SDGs.

2. Controversy analysis, as ESG analysis providers refer to those events or situations in which a company's operations or products may have a negative impact in environmental, social or corporate governance terms. For all investments in the fund, the number and seriousness of the controversies detected will be continuously assessed, ensuring that no investment classified as “sustainable investment” may cause significant harm in ESG terms based on such controversies.

3. The requirement of a minimum ESG rating that helps to ensure that the fund's investments meet minimum standards in the management of environmental, social and corporate governance aspects, thereby eliminating the lowest-performing companies in the management of these factors and that, consequently, can cause significant damage to them.

4. The individual analysis of the quality of corporate governance of the investments made and the requirement that adequate standards are met in terms of ownership structure, management and control bodies, human resources management, accounting and fiscal transparency, as well as business ethics. These characteristics are assessed and scored within the breakdown of the ESG rating, and make it possible to set up an additional filter to ensure that the fund's intended sustainable investments comply with good governance practices.

5. The consideration of the Principal Adverse Impacts (PAIs) on sustainability factors.

6. The application of the Manager's exclusion policy, as detailed below, excludes any companies with significant exposure to economic activities with a highly negative impact in environmental or social terms.

Consideration of the Principal Adverse Impact indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

The management team will take account of the indicators listed in Table 1 and any of those listed in Tables 2 and 3 of Annex I to Delegated Regulation (EU) 2022/1288. The Do No Significant Harm principle is introduced into the investment classification process as “sustainable investments” or as “investments with other environmental or social characteristics”. The assessment of the Do No Significant Harm principle is part of the three pillars underpinning compliance with the regulatory definition of “sustainable investment”.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

Last update: 31/05/2023.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

Last update: 31/05/2023.

Initially, the Manager's exclusion policy is applied, ruling out companies with significant exposure to economic activities with a highly negative environmental or social impact. These activities include the production of weapons of mass destruction, the production of weapons considered controversial due to their impact on the civilian population, the generation of electricity from highly polluting sources or the exploration and production of oil and gas in areas or using techniques with a high ecological impact. Also excluded are any companies about which there is evidence that they do not respect the fundamental human rights defined by the United Nations or that do not comply with labour rights as defined in the Conventions of the International Labour Organization.

The fund then follows a “best-in-class” investment process, which consists of selecting companies with the best assessment in terms of sustainability according to the aforementioned indicator. At least 60% of the portfolio's assets will have a rating equal to or higher than the minimum set out in the “Monitoring the environmental or social characteristics” section and, within this majority share of the portfolio, sustainable investments must make a positive net contribution to the 17 SDGs set out above, which will account for at least 20% of the Fund's assets.

In addition to the ex-ante assessment, prior to the investment decision, the management team performs a continuous assessment of the portfolio to analyse its alignment with the promoted sustainable characteristics.

The management team considers the good governance practices at the invested companies, via the indicator used (ESG Rating) for selecting investments. Specifically, when assessing the good governance of companies, ESG ratings include a specific section where aspects related to business ethics and the quality of corporate governance are taken into account. Here, various issues are assessed, such as the characteristics of the company's ownership structure, the operating characteristics and the composition of the control bodies, remuneration policies, accounting and fiscal transparency, the existence of control policies and mechanisms that effectively prevent actions in breach of business ethics as well as the existence of disputes related, for example, to cases of bribery, corruption, fraud, money laundering or anti-competitive practices.

Last update: 31/05/2023.

Investments that promote sustainable characteristics will make up at least 60% of the assets in the portfolio. These investments will materialise in at least 20% of the fund's assets in sustainable investments with a social and/or environmental aim, in accordance with the definition of the applicable Regulation (EU) 2019/88.

The fund does not use derivatives to achieve the environmental or social characteristics pursued.

Last update: 31/05/2023.

With a view to implementing the investment strategy and achieving the intended environmental and social characteristics, the management team has set the following requirements:

• All investments considered have a minimum ESG Rating of “BBB” on a scale ranging from AAA to CCC, with AAA being the best and CCC being the worst, or equivalent depending on the scale of the chosen ESG analytics provider(s).
• The portfolio has, in aggregate and on average, a minimum ESG Rating of “A” or equivalent depending on the scale of the chosen ESG analysis provider(s).

Any individual investment that does not reach the minimum required rating cannot be considered as adequately promoting the environmental and social characteristics and will no longer be included in the section on “Investments adjusted for environmental or social characteristics”. In order to assess the permanence of these investments, the team will consider the compliance with the portfolio's joint minimum rating target and the minimum proportion of 60% of the equity assigned to assets of “Investments adjusted for environmental or social characteristics”.

One of the fund's indicators is the appropriate compliance with the environmental and social characteristics pursued by the “ESG rating” for the companies it invests in.

Last update: 31/05/2023.

The “ESG rating” used as an indicator is a metric prepared by independent companies, specialised in the analysis of extra-financial risks. It offers a global assessment of the previously described environmental and social characteristics. However, the calculation methodology of an “ESG rating” differs depending on the provider. In general, all of them are based on identifying the most relevant environmental, social and governance variables, assessing and weighing them based on their relevance according to the sector or sub-industry to which the analysed company belongs. The final assessment is expressed in the form of a joint rating, although there is also the possibility of accessing individual scores for environmental, social and governance practices. The “ESG rating” is usually expressed in the form of letters or numbers depending on the provider, but in both cases, the values are expressed using a level scale to identify the degree of exposure to extra-financial risks faced by the analysed company, and its ability to manage them. Based on this scale, it is possible to determine if an investment has environmental, social and governance characteristics associated with a very low, low, medium, high or very high sustainability risk, and promote the selection of those that best fit the fund's goals.

With regard to Public Fixed Income, in addition to the “ESG rating” of the issuing companies, there are labels (green, social, sustainable) associated with specific emissions that contribute to and reinforce the identification of the investment's environmental or social characteristics.

The asset management vehicle arranged only uses external providers to determine ESG ratings and therefore does not develop its own methodology for these ratings.

As regards the methodology to assess the characteristics required of “sustainable investments”, and taking into account that their regulatory definition states that:
(1) the investment must be made in an economic activity that contributes to an environmental or social goal;
(2) the investment must not significantly harm any environmental or social goal (assessed based on the DNSH principle through the aforementioned indicators) and
(3) the investee company must follow good governance practices.

The asset management vehicle arranged implements its classification methodology based on the control and monitoring of:
(1) the net contribution to the Sustainable Development Goals as outlined in the relevant section.
(2) the favourable or unfavourable comparison in relative terms of the most significant metrics listed in Table 1 of Appendix I to Delegated Regulation (EU) 2022/1288, such as the intensity of greenhouse gas emissions, violations of the principles of the United Nations Global Compact, the lack of compliance processes and mechanisms to track compliance with these principles, the gender diversity of the board of directors or exposure to controversial weapons, and
(3) a check through the ESG rating and the analysis of controversies that good governance practices are properly followed.

The investment process takes account of these two methodologies, and the Manager monitors their compliance on a monthly basis. Additionally, an annual report is released on the degree of achievement of the investment strategy and the social or environmental characteristics promoted by the fund.

Last update: 30/11/2024.

MSCI ESG Research, a reputable third-party provider, provides non-financial data for the underlying assets in which the plan invests to assess whether the characteristics promoted by the plan have been attained and to assess these underlying assets using the aforementioned “ESG ratings”. Non-financial data cover all data concerning environmental, social and corporate governance issues and, as a result, also include data concerning “principal adverse impacts”.

As a result, the quality of these data hinges upon the provider chosen and whether these data are published by companies or issuers. When specific data are not published by companies or issuers, estimates may be required that may be significantly different from the figures ultimately published. The asset management vehicle arranged does not produce its own estimates and instead uses estimates from its external providers. In order to ensure that the data are high quality, the asset management vehicle arranged uses reputable external providers, monitoring and comparing how available and up-to-date the data provided by each of them are.

For indirect investments through CISs classified as Article 8 or 9 of Regulation (EU) 2019/88 products, data provided by their respective management companies are used.

The proportion of estimated data used from the providers, as well as from the management companies relating to investments in CISs is a tricky parameter to establish with the information currently available.

Last update: 31/05/2023.

The methods used, and which have been described above, may present limitations and consequently may require modifications over time. The right measurement of how the social or environmental characteristics promoted by the fund are met may be limited by the availability and quality of the extra-financial information used to assess the ESG characteristics of the underlying assets in which it invests and/or of the asset issuers. The classification of assets as “sustainable investments” also requires a significant volume of data and assessment criteria that are not agreed upon at the European level, which can make the comparison between plans from different financial institutions complex.

In order for these limitations not to affect how the environmental or social characteristics promoted by the fund are met, the Manager constantly analyses and monitors the results achieved and establishes periodic checks on the percentage of assets that meet said characteristics, as well as the percentage of sustainable investments, confirming that both percentages meet the established thresholds.

Last update: 31/05/2023.

Regarding the due diligence measures for the fund's underlying assets, the Manager has established an ex-ante control that does not allow the trading of an asset if this means that the fund does not meet the thresholds established in section “Monitoring environmental or social characteristics".

Also, a periodic ex-post control is carried out, considering sudden drops in the ESG rating of the financial assets that make up the fund's portfolio.

And the information provided by external providers is periodically updated to improve the coverage of the underlying assets that the fund invests in.

Last update: 31/05/2023.

The Management Company will monitor certain aspects of the business strategies, performance and financial and non-financial risk, capital structure, social and environmental impact and corporate governance of specific companies, to the extent it deems appropriate considering its investment strategy and the nature and size of its investment in them.

To perform this monitoring work, the Management Company may use various sources and mechanisms, e.g. the review of non-financial information, particularly as regards ESG Risks and Factors.

The Management Company interprets its fiduciary duty with respect to the unit holders of the Managed Vehicles as an effort to maximise the value of their investments in both the long and short term, in compliance with its management and administration responsibilities, not only as a shareholder but also by actively participating with the company's management.

The Management Company is aware that, through participation in the Annual General Meetings or in engagement with the companies,“” faster growth and higher profitability are possible in the long run. The Management Company believes it is possible to improve long-term profitability and generate a positive impact on sustainability by integrating sustainability risks and factors into its Managed Vehicles and the investee companies.

Last update: 31/05/2023.

No specific benchmark index has been identified for establishing the plan's environmental and social characteristics.

Statement on the Main Adverse Impacts of Investment Decisions on Sustainability Factors 30 June 2023.

Statement of the Main Adverse Impacts of Investment Advice on Sustainability Factors 30 June 2023.

Statement of Principal Adverse Impacts of investment advice on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2026.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2026.

Last update: 30/11/2024.

This pension fund (hereinafter, the “Fund”), promotes environmental characteristics, and is classified as an Article 8 of Regulation (EU) 2019/2088 financial product. However, it does not have a sustainable investment objective.

Nevertheless, even though the Fund does not have a sustainable investment objective, it intends to make sustainable investments. The Fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

Within these investments, any potential damage caused must not be significant and must always be mitigated by the greater positive impact generated, in order to not significantly undermine any environmental or social sustainable investment goal, given that the Fund requires all sustainable investments to make a net positive contribution to the sustainable goals being pursued.

Additionally, consideration of the Main Adverse Incidents indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

In order to ensure compliance with the environmental or social characteristics promoted by the Fund, the initial step in the investment strategy involves applying the Fund Manager's exclusion policy, which excludes companies with high exposure to economic activities which have a significantly negative environmental or social impact, or which violate fundamental human or labour rights. The Fund then follows a “best-in-class” investment process.

The management team takes the good governance practices at the companies in which it invests into account, via the indicator used (ASG Rating) for selecting investments. When considering the planned investment ratio for the portfolio, at least 60% of the portfolio's assets is established for investments that promote environmental or social characteristics, and a minimum of 20% of its assets is specified for sustainable investments.

The ESG Rating indicator, which must meet the minimum required value both for each individual asset and at an overall level for the entire portfolio, is used for monitoring the environmental or social characteristics promoted by the Fund.

The fund uses methods which have been specifically developed both for measuring both compliance with environmental or social characteristics, where the “ESG rating” indicator is used as a metric, and for assessing the sustainable investments based on their net positive contribution towards the 17 SDGs.

In order to deploy these methods, the Fund Manager uses data from reputable suppliers. However, there may be constraints on the availability and quality of the non-financial information used for assessing the ESG Rating indicator and sustainable investments. The Fund Manager continuously analyses and monitors the results from these assessments in order mitigate these constraints.

The Fund Manager has a due diligence measure targeting the Fund's underlying assets, which involves continuously monitoring them and their compliance with the environmental and social characteristics promoted by the Fund.

The Fund Manager also has an Engagement Policy which contains processes focussing on active dialogue with issuers (“engagement”) and on voting on potential companies in which to invest.

No specific benchmark index has been identified for establishing the Fund's environmental and social characteristics.

Last update: 30/11/2024.

This financial product promotes environmental or social characteristics, but does not aim at sustainable investment.

However, the fund plans to make sustainable investments. The fund's sustainable investments set out to further all of the Sustainable Development Goals (SDGs) outlined within the United Nations 2030 Agenda. There are 17 SDGs, including the following: 1) no poverty; 2) end hunger; 3) ensure health and well-being; 4) guarantee education; 5) achieve gender equality, 6) guarantee the availability and sustainable management of water; 7) guarantee access to affordable and sustainable energy; 8) promote economic growth and decent employment; 9) promote industry, innovation and infrastructure; 10) reduce inequalities; 11) achieve inclusive, safe and sustainable cities and communities; 12) guarantee sustainable consumption and production patterns; 13) take measures to combat climate change and its effects; 14) conserve and sustainably use the oceans, seas and marine resources; 15) sustainably manage forests, combat desertification and land degradation; 16) promote justice and peace through institutions and 17) contribute to the Global Partnership for Sustainable Development.

By making this type of sustainable investment, the fund aims to make a positive contribution to the SDGs. To identify these investments, the fund uses an indicator from an external provider, specialised in ESG analysis, with a methodology used to measure the contribution of companies to each of the 17 SDGs, based on their operations, products, services, policies and practices implemented to address these challenges. Based on the above, each company analysed has a positive or negative metric for each of the 17 goals. An investment must make a net positive contribution to the 17 SDGs in order to qualify as a sustainable investment.

To the extent that the fund requires that any sustainable investment make a net positive contribution to the sustainable goals, this means that the potential damage generated will not be significant, and will always be mitigated by the greater positive impact generated.

In addition to presenting a positive net contribution to the 17 SDGs, the fund's sustainable investments will comply with the principle of Do No Significant Harm to another sustainability goal, which will be achieved through the combination of the following management actions:

1. The very requirement of a positive net contribution to the 17 SDGs, which implies that the potential damage generated to one or several SDGs will not be significant and will always be mitigated by the greater positive impact generated to other SDGs.

2. Controversy analysis, as ESG analysis providers refer to those events or situations in which a company's operations or products may have a negative impact in environmental, social or corporate governance terms. For all investments in the fund, the number and seriousness of the controversies detected will be continuously assessed, ensuring that no investment classified as “sustainable investment” may cause significant harm in ESG terms based on such controversies.

3. The requirement of a minimum ESG rating that helps to ensure that the fund's investments meet minimum standards in the management of environmental, social and corporate governance aspects, thereby eliminating the lowest-performing companies in the management of these factors and that, consequently, can cause significant damage to them.

4. The individual analysis of the quality of corporate governance of the investments made and the requirement that adequate standards are met in terms of ownership structure, management and control bodies, human resources management, accounting and fiscal transparency, as well as business ethics. These characteristics are assessed and scored within the breakdown of the ESG rating, and make it possible to set up an additional filter to ensure that the fund's intended sustainable investments comply with good governance practices.

5. The consideration of the Principal Adverse Impacts (PAIs) on sustainability factors.

6. The application of the Manager's exclusion policy, as detailed below, excludes any companies with significant exposure to economic activities with a highly negative impact in environmental or social terms.

Consideration of the Principal Adverse Impact indicators is taken into account throughout the entire investment process, in order to manage the key indicators for the Do No Significant Harm (DNSH) assessment.

The management team will take account of the indicators listed in Table 1 and any of those listed in Tables 2 and 3 of Annex I to Delegated Regulation (EU) 2022/1288. The Do No Significant Harm principle is introduced into the investment classification process as “sustainable investments” or as “investments with other environmental or social characteristics”. The assessment of the Do No Significant Harm principle is part of the three pillars underpinning compliance with the regulatory definition of “sustainable investment”.

To the extent that sustainable investments are also subject to sustainability analysis through the ESG Rating“” indicator, which incorporates environmental, social and governance criteria compatible with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight core conventions referred to in the ILO Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights, the team analyses the alignment of the investee companies with these principles and guidelines.

Last update: 31/05/2023.

By assessing the business practices of the companies in which it invests, the Fund promotes environmental and social characteristics such as carbon efficiency, properly managing how natural resources and water are consumed, limiting the impact on biodiversity and land use, properly managing waste and toxic emissions, limiting the impact of pollution caused by non-recyclable packaging and materials, properly managing human resources in order to keep workplace risks under control and complying with labour rights, appropriately managing relationships with wider society and the company's impact on it in order to, for example, prevent violations of fundamental rights, reducing potential damages caused by a lack of suitable health and safety measures in the products and services offered, suitable protection for keeping customer data private and secure and/or monitoring of these protection systems within its supply chains.

Last update: 31/05/2023.

Initially, the Manager's exclusion policy is applied, ruling out companies with significant exposure to economic activities with a highly negative environmental or social impact. These activities include the production of weapons of mass destruction, the production of weapons considered controversial due to their impact on the civilian population, the generation of electricity from highly polluting sources or the exploration and production of oil and gas in areas or using techniques with a high ecological impact. Also excluded are any companies about which there is evidence that they do not respect the fundamental human rights defined by the United Nations or that do not comply with labour rights as defined in the Conventions of the International Labour Organization.

The fund then follows a “best-in-class” investment process, which consists of selecting companies with the best assessment in terms of sustainability according to the aforementioned indicator. At least 60% of the portfolio's assets will have a rating equal to or higher than the minimum set out in the “Monitoring the environmental or social characteristics” section and, within this majority share of the portfolio, sustainable investments must make a positive net contribution to the 17 SDGs set out above, which will account for at least 20% of the Fund's assets.

In addition to the ex-ante assessment, prior to the investment decision, the management team performs a continuous assessment of the portfolio to analyse its alignment with the promoted sustainable characteristics.

The management team considers the good governance practices at the invested companies, via the indicator used (ESG Rating) for selecting investments. Specifically, when assessing the good governance of companies, ESG ratings include a specific section where aspects related to business ethics and the quality of corporate governance are taken into account. Here, various issues are assessed, such as the characteristics of the company's ownership structure, the operating characteristics and the composition of the control bodies, remuneration policies, accounting and fiscal transparency, the existence of control policies and mechanisms that effectively prevent actions in breach of business ethics as well as the existence of disputes related, for example, to cases of bribery, corruption, fraud, money laundering or anti-competitive practices.

Last update: 31/05/2023.

Investments that promote sustainable characteristics will make up at least 60% of the assets in the portfolio. These investments will materialise in at least 20% of the fund's assets in sustainable investments with a social and/or environmental aim, in accordance with the definition of the applicable Regulation (EU) 2019/88.

The fund does not use derivatives to achieve the environmental or social characteristics pursued.

Last update: 31/05/2023.

With a view to implementing the investment strategy and achieving the intended environmental and social characteristics, the management team has set the following requirements:

• All investments considered have a minimum ESG Rating of “BBB” on a scale ranging from AAA to CCC, with AAA being the best and CCC being the worst, or equivalent depending on the scale of the chosen ESG analytics provider(s).
• The portfolio has, in aggregate and on average, a minimum ESG Rating of “A” or equivalent depending on the scale of the chosen ESG analysis provider(s).

Any individual investment that does not reach the minimum required rating cannot be considered as adequately promoting the environmental and social characteristics and will no longer be included in the section on “Investments adjusted for environmental or social characteristics”. In order to assess the permanence of these investments, the team will consider the compliance with the portfolio's joint minimum rating target and the minimum proportion of 60% of the equity assigned to assets of “Investments adjusted for environmental or social characteristics”.

One of the fund's indicators is the appropriate compliance with the environmental and social characteristics pursued by the “ESG rating” for the companies it invests in.

Last update: 31/05/2023.

The “ESG rating” used as an indicator is a metric prepared by independent companies, specialised in the analysis of extra-financial risks. It offers a global assessment of the previously described environmental and social characteristics. However, the calculation methodology of an “ESG rating” differs depending on the provider. In general, all of them are based on identifying the most relevant environmental, social and governance variables, assessing and weighing them based on their relevance according to the sector or sub-industry to which the analysed company belongs. The final assessment is expressed in the form of a joint rating, although there is also the possibility of accessing individual scores for environmental, social and governance practices. The “ESG rating” is usually expressed in the form of letters or numbers depending on the provider, but in both cases, the values are expressed using a level scale to identify the degree of exposure to extra-financial risks faced by the analysed company, and its ability to manage them. Based on this scale, it is possible to determine if an investment has environmental, social and governance characteristics associated with a very low, low, medium, high or very high sustainability risk, and promote the selection of those that best fit the fund's goals.

With regard to Public Fixed Income, in addition to the “ESG rating” of the issuing companies, there are labels (green, social, sustainable) associated with specific emissions that contribute to and reinforce the identification of the investment's environmental or social characteristics.

The asset management vehicle arranged only uses external providers to determine ESG ratings and therefore does not develop its own methodology for these ratings.

As regards the methodology to assess the characteristics required of “sustainable investments”, and taking into account that their regulatory definition states that:
(1) the investment must be made in an economic activity that contributes to an environmental or social goal;
(2) the investment must not significantly harm any environmental or social goal (assessed based on the DNSH principle through the aforementioned indicators) and
(3) the investee company must follow good governance practices.

The asset management vehicle arranged implements its classification methodology based on the control and monitoring of:
(1) the net contribution to the Sustainable Development Goals as outlined in the relevant section.
(2) the favourable or unfavourable comparison in relative terms of the most significant metrics listed in Table 1 of Appendix I to Delegated Regulation (EU) 2022/1288, such as the intensity of greenhouse gas emissions, violations of the principles of the United Nations Global Compact, the lack of compliance processes and mechanisms to track compliance with these principles, the gender diversity of the board of directors or exposure to controversial weapons, and
(3) a check through the ESG rating and the analysis of controversies that good governance practices are properly followed.

The investment process takes account of these two methodologies, and the Manager monitors their compliance on a monthly basis. Additionally, an annual report is released on the degree of achievement of the investment strategy and the social or environmental characteristics promoted by the fund.

Last update: 30/11/2024.

MSCI ESG Research, a reputable third-party provider, provides non-financial data for the underlying assets in which the plan invests to assess whether the characteristics promoted by the plan have been attained and to assess these underlying assets using the aforementioned “ESG ratings”. Non-financial data cover all data concerning environmental, social and corporate governance issues and, as a result, also include data concerning “principal adverse impacts”.

As a result, the quality of these data hinges upon the provider chosen and whether these data are published by companies or issuers. When specific data are not published by companies or issuers, estimates may be required that may be significantly different from the figures ultimately published. The asset management vehicle arranged does not produce its own estimates and instead uses estimates from its external providers. In order to ensure that the data are high quality, the asset management vehicle arranged uses reputable external providers, monitoring and comparing how available and up-to-date the data provided by each of them are.

For indirect investments through CISs classified as Article 8 or 9 of Regulation (EU) 2019/88 products, data provided by their respective management companies are used.

The proportion of estimated data used from the providers, as well as from the management companies relating to investments in CISs is a tricky parameter to establish with the information currently available.

Last update: 31/05/2023.

The methods used, and which have been described above, may present limitations and consequently may require modifications over time. The right measurement of how the social or environmental characteristics promoted by the fund are met may be limited by the availability and quality of the extra-financial information used to assess the ESG characteristics of the underlying assets in which it invests and/or of the asset issuers. The classification of assets as “sustainable investments” also requires a significant volume of data and assessment criteria that are not agreed upon at the European level, which can make the comparison between plans from different financial institutions complex.

In order for these limitations not to affect how the environmental or social characteristics promoted by the fund are met, the Manager constantly analyses and monitors the results achieved and establishes periodic checks on the percentage of assets that meet said characteristics, as well as the percentage of sustainable investments, confirming that both percentages meet the established thresholds.

Last update: 31/05/2023.

Regarding the due diligence measures for the fund's underlying assets, the Manager has established an ex-ante control that does not allow the trading of an asset if this means that the fund does not meet the thresholds established in section “Monitoring environmental or social characteristics".

Also, a periodic ex-post control is carried out, considering sudden drops in the ESG rating of the financial assets that make up the fund's portfolio.

And the information provided by external providers is periodically updated to improve the coverage of the underlying assets that the fund invests in.

Last update: 31/05/2023.

The Management Company will monitor certain aspects of the business strategies, performance and financial and non-financial risk, capital structure, social and environmental impact and corporate governance of specific companies, to the extent it deems appropriate considering its investment strategy and the nature and size of its investment in them.

To perform this monitoring work, the Management Company may use various sources and mechanisms, e.g. the review of non-financial information, particularly as regards ESG Risks and Factors.

The Management Company interprets its fiduciary duty with respect to the unit holders of the Managed Vehicles as an effort to maximise the value of their investments in both the long and short term, in compliance with its management and administration responsibilities, not only as a shareholder but also by actively participating with the company's management.

The Management Company is aware that, through participation in the Annual General Meetings or in engagement with the companies,“” faster growth and higher profitability are possible in the long run. The Management Company believes it is possible to improve long-term profitability and generate a positive impact on sustainability by integrating sustainability risks and factors into its Managed Vehicles and the investee companies.

Last update: 31/05/2023.

No specific benchmark index has been identified for establishing the plan's environmental and social characteristics.

Statement on the Main Adverse Impacts of Investment Decisions on Sustainability Factors 30 June 2023.

Statement of the Main Adverse Impacts of Investment Advice on Sustainability Factors 30 June 2023.

Statement of Principal Adverse Impacts of investment advice on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2024.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2025.

Statement of Principal Adverse Impacts of investment advices on sustainability factors 30th June 2026.

Statement of Principal Adverse Impacts of investment decisions on sustainability factors 30th June 2026.