JMS Invest promotes with their managed funds environmental and social characteristics subject to good governance practices within the meaning of Article 8 of the Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial sector.

 We invest with a singular objective to optimize the risk/return profile for our clients in a responsible manner by considering environmental, social, and corporate governance (“ESG”) characteristics. We balance this with an understanding of the risks taken to achieve this objective. The incorporation of ESG factors forms an integral part of the investment management approach, as we truly believe that financial analysis and ESG assessment are intertwined in judging the relative attractiveness of a company.

 JMS Invest has implemented a proprietary ESG scoring model for each individual company in which investments are made. ESG topics are captured and assessed qualitatively and fundamentally, bottom up based on primary and secondary research. The materiality of a particular ESG issue varies from industry to industry, therefore we believe it is important to integrate ESG factors into the company assessment rather than as a pre-screen or overlay. The scoring model ranges from CCC to AAA.

 Our ESG risk approach is to encourage companies to explain how their approach to sustainability relates to the broader business strategy and to provide them with an opportunity to comment on ESG-related findings in order to fully reflect the potential complexity of an ESG issue. These comments have an impact on the decision of the investment management team to enter either into a long or into a short position. Furthermore, this ESG analysis forms an integral part of the monitoring process of existing portfolio holdings.

 A substantial part of the equity portfolio holdings held by a sub-fund are subject to above mentioned ESG analysis. Although we focus on Small and Mid Caps where ESG data quality is generally weak, we strive to assess ESG risks based on our bottom-up research approach. Nevertheless, for some companies, a full in-depth ESG analysis will not be possible and in these cases an inhouse ESG scoring will not be performed. These cases can comprise a substantial part of the portfolio. The Investment Manager also shall consider ESG factors when using derivatives for speculative purposes. In this case, short positions through derivatives on single issuers are covered the same way as long positions. Derivatives used for hedging purposes, baskets and index-based products or cash accounts are excluded from ESG analysis.

 Our strategy aims to maintain an aggregate, position weighted internal ESG score of at least “A”. The internal ESG score of an individual investment held by the sub-funds can be below the minimum score stated above.

 In addition to our ESG integration approach, the Exclusion approach (“Negative Screening Strategy”) is also applied. Norm-based exclusion criteria are used for all our managed funds. We exclude investments involving controversial and nuclear weapons as well as controversial countries. Based hereon, we do not invest in nuclear weapons, biological or chemical weapons, anti-personnel mines, and cluster amunitions. The Swiss Law “Bundesgesetz über das Kriegsmaterial (KMG)” of December 13, 1996 (as of February 1, 2013) forms the basis for JMS Invest’s norm-based exclusions.

 Please do not hesitate to contact us for further questions regarding our sustainability investment policy.