Sustainability-Related Disclosures
To comply with the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended (“SFDR”), Fisher Investments Luxembourg, Sàrl (“FIL”) has provided the below sustainability-related disclosures. FIL is authorised to provide portfolio management services and, in select jurisdictions, insurance intermediation services. FIL provides such services to high net worth private clients (“private clients”).
Information on Sustainability Risk Policies
Portfolio Management Services:
Because FIL delegates its portfolio management services to its parent company, Fisher Asset Management, LLC, trading as Fisher Investments (“FI”), subject to FIL’s oversight, such policies and strategies are implemented by FI, but apply to FIL’s portfolio management services provided to FIL’s private clients.
FI considers environmental, social and governance (“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.
Insurance Intermediation Services:
FIL does not consider Sustainability Risk as part of its insurance advice. FIL recommends only insurance contracts, provided by its partner insurers, that include an invested mandate, as per FIL and its partner insurers agreement, managed by FIL’s asset management division. While ESG factors, including Sustainability Risk, are considered throughout the investment process for each invested mandate available in the insurance contracts (similarly to how Sustainability Risk is considered for FIL’s portfolio management services), the assessed degree of Sustainability Risk for each such invested mandate is currently the same, making the assessment of Sustainability Risk between potential insurance contracts meaningless.
Information on Integration of Sustainability Risk in FIL’s Remuneration Policy
Portfolio Management Services:
Given that FIL outsources the portfolio management function to FI, it is not envisaged that there will be scenarios where the consideration of Sustainability Risks is relevant to the functions performed by FIL staff. Accordingly, FIL does not anticipate factoring consideration of Sustainability Risks into the assessment of FIL’s staff members’ variable remuneration.
Insurance Intermediation Services:
Due to FIL not considering Sustainability Risk as part of its insurance advice, FIL does not anticipate factoring consideration of Sustainability Risk into the assessment of FIL’s staff members’ variable remuneration.
Disclosure of the Consideration of Adverse Impacts on Sustainability Factors
Portfolio Management Services:
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 FIL’s size, FIL 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 also 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.
Insurance Intermediation Services:
No Consideration of Adverse Impacts of Insurance Advice on Sustainability Factors
When providing insurance intermediation services, FIL works exclusively with only certain insurance companies and recommends only insurance contracts that include an invested mandate managed by the asset management division of FIL. Because the invested mandates included in the insurance contracts recommended by FIL currently do not consider any adverse impacts on Sustainability Factors, FIL does not consider any adverse impacts such insurance contract may have on Sustainability Factors when providing insurance advice. Should the invested mandates available in the insurance contracts recommended by FIL expand to include those that consider adverse impacts on Sustainability Factors, FIL may begin to consider adverse impacts on Sustainability Factors in its insurance advice.
Sustainability-Related Disclosures
Portfolio Management Services:
FIL 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 an RI Strategy in a private client’s investment portfolio, such portfolio is considered to be an Article 8 financial product under SFDR, which requires certain portfolio-specific disclosures to be provided on FIL’s website. However, FIL 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, FIL 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.
Global Sustainable Equity Impact ESG
Insurance Intermediation Services:
For any private clients who are interested in FIL’s insurance intermediation services, such private clients should go to the insurance contract provider’s website for any sustainability-related disclosures related to the insurance contracts FIL may recommend as part of its insurance advice.
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 FIL’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;
- remove disclosures not required under SFDR or the Taxonomy Regulation (Regulation EU/2020/852); and
- add disclosures for FIL’s insurance intermediation services.
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 FIL.
Date of Publication: 9 February 2026