1.General Background

The Sustainable Finance Disclosure Regulation (“SFDR”) imposes disclosure requirements on financial product manufacturers aimed at informing end-investors about sustainability considerations. SFDR mandates that relevant firms reveal how they incorporate sustainability into their investment processes and assess the adverse impacts of investments on sustainability factors. SFDR is applicable to financial market participants offering portfolio management services.

Aistocks, a provider of CopyPortfolio and CopyTrading services. Consequently, Aistocks is obligated under SFDR to make specific disclosures, as outlined in this document. However, the subsequent disclosures clarify how SFDR obligations, if applicable, pertain to both the CopyTrading and CopyPortfolio services.

2. Entity Level Disclosures

1. A) In accordance with SFDR Article 3: Financial market participants must publicly disclose information on their policies regarding the integration of sustainability risks into their investment decision-making processes.

Disclosure: Aistocks takes into account the impact of sustainability on the markets in which it operates, as well as on the products and services it offers. However, Aistocks does not maintain a distinct policy regarding the integration of sustainability risks into investment decision-making processes. According to SFDR, “sustainability risk” refers to “an environmental, social, or governance event or condition that, if it occurs, could result in an actual or potential material negative impact on the value of the investment.”

For CopyTrading services, Aistocks does not exercise discretion over the investment decisions made by Copy Accounts and, therefore, does not incorporate sustainability risk into investment decisions.

Regarding CopyPortfolio services, Aistocks does not include sustainability risk in its decision-making process for portfolio composition. However, we will closely monitor this stance in response to any increased demand for environmentally friendly or sustainable portfolios.

1. B) As per SFDR Article 4: Financial market participants are required to maintain and publish on their websites:

(a) information about their due diligence policies regarding the consideration of principal adverse impacts of investment decisions on sustainability factors, taking into account their size, the nature and scale of their activities, and the types of financial products they offer; or

(b) clear explanations of why they do not consider adverse impacts of investment decisions on sustainability factors, including information on whether and when they intend to address such impacts.

Disclosure: While Aistocks supports the transparency objectives of SFDR related to reporting quantitative metrics for portfolio investments, we do not currently assess principal adverse impacts of investment decisions on the environment and society, as defined by SFDR.

For CopyTrading services, Aistocks does not exercise discretion over the investment decisions made by Copy Accounts and, therefore, does not consider principal adverse impacts.

Concerning CopyPortfolio services, we do not assess principal adverse impacts in the composition of any portfolio. Our assessment is based on the notion that many of the required metrics in the draft legislation are not readily available and may not be pertinent to investors.

Nevertheless, Aistocks does consider the general impact of its investment activities on the environment and society, as further explained below and in our disclosure regarding the integration of sustainability risk above. Our position on SFDR disclosure will remain under review.

1. C) Under SFDR Article 5, financial market participants and financial advisers must include information in their remuneration policies regarding the alignment of those policies with the integration of sustainability risks, and they must publish this information on their websites.

Disclosure: Aistocks’ remuneration policy promotes sound and effective risk management while discouraging risk-taking inconsistent with the risk profile of the products or services offered. Although the policy does not explicitly consider sustainability risks, it applies the principle of effective risk management to sustainability risk in the same manner as other forms of risk.

3. Product Level Disclosures

1. A) According to SFDR Article 6: Financial market participants should provide descriptions of the following in pre-contractual disclosures:

(a) how sustainability risks are integrated into their investment decisions; and

(b) the results of the assessment of the likely impacts of sustainability risks on the returns of the financial products they offer. If sustainability risks are deemed irrelevant, the descriptions should include a clear and concise explanation of the reasons.

Disclosure:

For CopyTrader products, Aistocks does not exercise discretion over the investment decisions made by Copy Accounts, and therefore, sustainability risks are not integrated into investment decisions. Consequently, Aistocks cannot assess the likely impacts of sustainability risks on the product’s returns due to the lack of discretion over Copy Account investments.

For CopyPortfolio products, Aistocks does not integrate sustainability risks into its decisions regarding portfolio composition. As a result, we do not provide a description of the results of a risk assessment related to the likely impacts of sustainability risks on the returns of the copy portfolio.

1. B) Regarding SFDR Article 8, where a financial product promotes environmental or social characteristics, or a combination thereof, provided that the underlying companies adhere to good governance practices, disclosures must include:

(a) information on how these characteristics are met;

(b) information on whether and how an index designated as a reference benchmark aligns with these characteristics.

Disclosure: Not applicable – Aistocks does not classify its CopyTrader or CopyPortfolio products as within the scope of Article 8 at this time.

1. C) For SFDR Article 9, when a financial product has sustainable investment as its objective and an index is designated as a reference benchmark, the accompanying disclosures under Article 6(1) and (3) should include:

(a) information on how the designated index aligns with the sustainable investment objective;

(b) an explanation of why and how the designated index aligns with the objective, differing from a broad market index.

Disclosure: Not applicable – Aistocks does not classify its CopyTrader or CopyPortfolio products as within the scope of Article 9 at this time.