Sustainability-Related Disclosures
To comply with the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended (“SFDR”), Fisher Investments Ireland Limited (“FII”) has provided the below sustainability-related disclosures that describe various policies related to sustainability and environmental, social and governance (“ESG”) factors, as well as information on Responsible Investment strategies (a “Responsible Investment Strategy,” or “RI Strategy”), FII has available to high net worth private clients (“private clients”). Because FII delegates its portfolio management services to its parent company, Fisher Asset Management, LLC, trading as Fisher Investments (“FI”), subject to FII’s oversight, such policies and strategies are implemented by FI, but apply to FII’s services provided to FII’s private clients.
If you are an institutional client of FII, please go to the following website to find FII’s SFDR and Taxonomy Regulation disclosures relevant to you: https://www.fisherinvestments.com/en-ie/institutional-investing/responsible-investing.
Information about FI’s Policies on the Integration of Sustainability Risks in its Investment Decision-making Process
FI considers ESG events or conditions that, if they occur, could cause a negative material impact on the value of an investment (“Sustainability Risk”), throughout the investment process.
FI believes that Sustainability Risk is not a standalone risk easily quantified at the security or portfolio level. Instead, Sustainability Risk manifests through other existing sustainability-related risk types, including but not limited to, political and economic factors, corruption and organised crime, ESG data reliance, and credit. As a result, FI assesses that a strategy with more investments susceptible to these underlying risk types may have greater Sustainability Risks due to their geographic exposures which may increase or decrease over time.
These risks are integrated in FI’s investment process and risk management practices both qualitatively and quantitatively. Qualitatively, FI considers such risks when developing country, sector, and thematic preferences and in their bottom-up fundamental research. Quantitatively, FI attempts to quantify and monitor Sustainability Risks as part of FI’s risk management practices.
While FI believes its investment and risk management practices can help enhance portfolio relative performance, particularly in modifying exposure to countries, industries, and securities whose value may be materially impacted by a related risk, Sustainability Risks may nonetheless adversely impact a strategy’s performance.
Information on Integration of Sustainability Risk in FII’s Remuneration Policy
Given that FII outsources the portfolio management function to FI, it is not currently envisaged that the consideration of Sustainability Risks will be of primary relevance to the functions performed by FII staff. Accordingly, FII does not currently anticipate consideration of Sustainability Risks as being a significant factor in the assessment of FII’s staff members’ variable remuneration.
No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors
Notwithstanding that the consideration of Sustainability Risks is integrated into FI’s investment decision-making process, by virtue of FII’s size, FII is not required and currently elects not to consider the adverse impacts of its investment decisions on environmental, social or employee matters, respect for human rights, or anti-corruption or anti-bribery matters (“Sustainability Factors”) in respect of all portfolios it manages. However, with respect to strategies that promote environmental or social characteristics or have a sustainable investment objective (a “Responsible Investment Strategy,” or “RI Strategy”), the sustainability-related disclosures provided below for each RI Strategy describes how principal adverse impacts on Sustainability Factors are considered by FI, including to what extent the indicators listed in Table 1 of Annex I of the Commission Delegated Regulation (EU) 2022/1288 (the “RTS”) are taken into consideration by FI. Furthermore, for private clients who have one or more RI Strategies implemented in their investment portfolio, such private clients will receive pre-contractual disclosures related to their investment portfolio that will describe how principal adverse impacts on Sustainability Factors are considered by FI in their investment portfolio.
Sustainability-Related Disclosures
FII makes available to its private clients certain Responsible Investment strategies (a “Responsible Investment Strategy,” or “RI Strategy”) that can be implemented in a private client’s investment portfolio. By implementing a RI Strategy in a private client’s investment portfolio, such portfolio is considered to be an Article 8 or Article 9 financial product under SFDR, which requires certain portfolio-specific disclosures to be provided on FII’s website. However, FII considers the management of its private client’s investment portfolio to be confidential, and will not publish portfolio-specific sustainability disclosures on its website. Instead, FII publishes the below information about the RI Strategies at the model level, which will include SFDR periodic reporting on the performance of such RI Strategies from a sustainability perspective.
Amendments to this Disclosure
Should any changes be made to this disclosure in the future, a clear explanation of such changes will be published here.
Implemented Changes
In January 2022, this disclosure was updated to reflect:
- the postponement of the RTS effective date to January 2023;
- SFDR Article 11 disclosures provided for the Responsible Investment Strategies;
- adding disclosures regarding the Taxonomy Regulation; and
- a change in FII’s SFDR categorization methodology for private client portfolios.
In December 2022, this disclosure was updated to:
- update the sustainability-related disclosures for the Responsible Investment Strategies to comply with the RTS;
- remove the principal adverse impact statement that was originally posted to comply with SFDR on a high level, principles basis; and
- remove disclosures not required under SFDR or the Taxonomy Regulation (Regulation EU/2020/852).
In February 2026, this disclosure was updated to:
- update the Investment Manager’s Responsible Investment Policy Statement (formerly the ESG Policy Statement); and
- refresh the Sustainability-Related Disclosures;
- and update the terminology to better align with defined terms from FI and FII.
Date of Publication: 9 February 2026