Sustainability Risk Policy
LWAM, a Cyprus Investment Firm (“CIF”) authorised and regulated by CySEC, integrates sustainability risks into its investment decision-making and advisory processes in accordance with SFDR Articles 3 and 5. Environmental, social, and governance (ESG) factors are systematically assessed and incorporated into the Firm’s risk management, governance, and advisory frameworks. Remuneration policies are aligned to support responsible investment and ensure that no incentives undermine the consideration of sustainability risks. These procedures are regularly reviewed to reflect evolving regulatory requirements, ESG best practices, and guidance from CySEC, including Circular C683
Principal Adverse Impact (PAI) Statement
LWAM is exempt from reporting Principal Adverse Impacts (PAIs) under the SFDR. Although a PAI Statement is not required, the Company remains committed to sustainability by integrating environmental, social, and governance (ESG) factors into its investment decisions and risk management, ensuring transparency and responsible investment practices.
Article 8 and Article 9 Product Disclosures
All LWAM financial products are classified under SFDR Articles 6, 8, or 9, and disclosures are prepared in line with the SFDR Delegated Regulation (EU 2022/1288). Article 8 products promote environmental or social characteristics, with disclosures detailing methodologies, metrics, and relevant indicators. Article 9 products pursue sustainable investment objectives, with disclosures explaining how these objectives are achieved while avoiding significant harm to other sustainability factors. Pre-contractual documents, website statements, and client communications are regularly updated to remain clear, accurate, and non-misleading.
Commitment to Transparency and Accountability
LWAM is committed to maintaining clear, accessible, and regulator-compliant disclosures at both the entity and product levels. By providing transparent information on sustainability risks, PAIs, and the environmental or social objectives of its financial products, LWAM ensures that clients and stakeholders can make informed decisions, while supporting responsible investment, regulatory compliance, and the integration of sustainability considerations across all operations.