Sustainability Risk Integration

Admirals Europe Ltd is authorised to provide Portfolio Management services under the Investment Services and Activities and Regulated Markets Law.

At present, the firm’s Portfolio Management service is inactive. As such, sustainability risks, as defined in Regulation (EU) 2019/2088 (“SFDR”), are not expected to have a material impact on investment decisions or on the performance of client portfolios.

The firm will integrate sustainability risks into its investment decision-making process and update its relevant internal procedures and disclosures once Portfolio Management services become active.

Principal Adverse Impacts (PAIs)

Admirals Europe Ltd does not currently consider principal adverse impacts (“PAIs”) of investment decisions on sustainability factors as set out in Article 4 of the SFDR.

This approach is due to the present inactive status of the Portfolio Management service and the absence of client portfolios under discretionary management.

The firm will reassess this position and may adopt a PAI framework when Portfolio Management services become active.

Sustainability and Remuneration

Admirals Europe Ltd maintains remuneration practices that are aligned with sound and effective risk management.

At this stage, sustainability risks do not influence the firm’s remuneration structure because Portfolio Management services are inactive and sustainability risks are not deemed materially relevant.

This position will be reviewed upon activation of the service.