Information on the approach to sustainability

in accordance with

Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector, effective from 10 March 2021.

Agropoistenie s.r.o., with its registered office at Sartorisova 11, 821 08 Bratislava (hereinafter the “company”), informs clients and potential clients interested in the intermediation of financial services about the Company's approach to sustainability issues in the area of financial services in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector, effective from 10 March 2021 (hereinafter the “Regulation”).

Reason for adopting legislation on the provision of information

Information on the integration of sustainability risks, on the consideration of adverse sustainability impacts, on sustainable investment objectives, or on the promotion of environmental or social characteristics, within investment decision-making and within the performance of financial intermediation, is published following a legislative initiative of the European Commission, according to which the disclosure of this information was not sufficiently developed.

Operation

Agropoistenie s.r.o. does not guarantee that the information and materials used are complete and that their content supplied by a third party is accurate and complete. Agropoistenie s.r.o. accepts no liability for the functions or materials available in this system, nor for their uninterrupted availability and freedom from errors.

Scope of information

The information is provided in connection with insurance products that have an investment component, and also in connection with pension products exposed to market fluctuations.

The company must provide the information because it is an obliged entity under the Regulation and intermediates the above-mentioned financial products.

Legal basis for disclosure of information

Under Article 3(2) of the Regulation, financial agents publish on their websites information on their policies on the integration of sustainability risks when carrying out financial intermediation.

Under Article 5 of the Regulation, the company publishes and retains on its website for a sufficiently long period:

information on whether, with due regard to their size, nature and scale of activities and the types of financial products in respect of which they provide advice, they consider in their investment or insurance advice the principal adverse impacts on sustainability factors, or
information on why, in their investment or insurance advice, they do not consider the adverse impacts of investment decisions on sustainability factors, and where applicable also information on whether and when they intend to consider such adverse impacts.

Explanation of terms

“sustainable investment” is an investment in an economic activity that contributes to an environmental objective, measured for example by key indicators on energy, renewable energy, raw materials, water and land use, on the production of waste and greenhouse gas emissions, on the impact on biodiversity and on the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality, or an investment that fosters social cohesion, social integration and labour relations, or an investment in human capital or in economically or socially disadvantaged communities, provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance.

“Sustainability risk” means an environmental, social or governance event or condition that, if it occurs, could cause a significant negative impact on the value of the investment.

“sustainability factors” are environmental, social and employee matters, respect for human rights, and anti-corruption and anti-bribery matters.

Transparency of policies relating to sustainability risks

The company has adopted a Directive on sustainability risks and, in accordance with the wording of the Regulation, publishes the relevant parts of that directive below in this publicly accessible notice.

Transparency of the integration of sustainability risks

In its pre-contractual disclosure of information, the company states in this document, in accordance with Article 6 of the Regulation:

the manner in which sustainability risks are integrated into its investment or insurance advice, and
the result of the assessment of the likely impacts of sustainability risks on the returns of the financial products in respect of which they provide advice.

When recommending a specific investment product, the Company also takes into account whether it aims to promote environmental or social characteristics, or whether it aims for a favourable impact on the environment, or whether it has neither of these aims.

When selecting insurance-based investment products, we evaluate the information provided by the manufacturer of the insurance-based investment product that relates to environmental or social impacts.

Whether the product manufacturer (insurer, securities dealer, etc.) takes sustainability risks into account is usually communicated in its pre-contractual information. The Company also builds on this information, in that, in accordance with the duty to act with professional care, it explains this information to the client when carrying out financial intermediation.

Provided that, when carrying out financial intermediation and setting out their requirements and needs during the client test in accordance with Section 35 of Act No. 186/2009 Coll. on Financial Intermediation and Financial Advisory, the client has not explicitly chosen that they prefer products that place risks in areas taking sustainability risks into account, the financial agent will take this into account when formulating recommendations for the client. The financial agent will act in particular with professional care and in the client's interest, in such a way as to offer the client the most advantageous product from their portfolio and to enable the client to conclude a financial service contract that best meets their needs and requirements. If several products with the same parameters are suitable for the client according to the client's requirements and the financial agent's duty to act with professional care, the financial agent will recommend to the client the product that aims to promote sustainability risks. The financial agent will take this into account when formulating the suitability statement and the periodic suitability statement.

Transparency of remuneration policies in relation to the integration of sustainability risks

Under Article 5 of the Regulation, the company provides information on the extent to which these policies are consistent with the integration of sustainability risks.

The company has also incorporated the consideration of sustainability risks into its remuneration principles. Within its remuneration policy, the company has set the following rules:

the company and its tied financial agents always act with professional care and in the interest of their clients,
if, when carrying out financial intermediation and setting out their requirements and needs during the client test in accordance with Section 35 of Act No. 186/2009 Coll. on Financial Intermediation and Financial Advisory, the client has explicitly chosen that they prefer products that place risks in areas taking sustainability risks into account, the remuneration mechanisms are set so as not to prevent the preference for investments in sustainability risks,
if, when carrying out financial intermediation and setting out their requirements and needs during the client test in accordance with Section 35 of Act No. 186/2009 Coll. on Financial Intermediation and Financial Advisory, the client has explicitly not chosen that they prefer products that place risks in areas taking sustainability risks into account, the remuneration mechanisms are set in such a way as to offer the client the most advantageous product from their portfolio and to enable the client to conclude a financial service contract that best meets their needs and requirements.
If several products with the same parameters are suitable for the client, the financial agent will recommend to the client the product that aims to promote sustainability risks.

Notice:

Under Article 3(2) of the Regulation, financial agents publish on their websites information on their policies on the integration of sustainability risks when carrying out financial intermediation.

The information set out in this document forms the necessary basis for taking sustainable investments into account within the company's processes.