Statement on Identifying and Managing Principal Adverse Sustainability Impacts

On March 10, 2021 the Regulation (EU) 2019/2088 of November 27, 2019 on sustainability-related disclosures in the financial sector (Disclosure Regulation) entered into force. This regulation aims to support sustainable investments by requiring Financial Market Participants (FMPs) to disclose information regarding sustainability risks and adverse sustainability impacts to investors and clients.

Principal adverse impacts on sustainability factors are referred to in Article 4 of the Disclosure Regulation and requires FMPs to publish and maintain on their websites:

(a) where they consider principal adverse impacts of investment decisions on sustainability factors, a statement on due diligence policies with respect to those impacts, taking due account of their size, the nature and scale of their activities and the types of financial products they make available; or

(b) where they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons for why they do not do so, including, where relevant, information as to whether and when they intend to consider such adverse impacts.

This approaches sustainability from the perspective of the harm that investment positions might do externally to "sustainability factors", being environmental, social and employee matters, respect for human rights, anti-corruption, and anti-bribery matters.

Given the limited size, nature and scale of Susquehanna International Securities Limited's (SIS) activities, SIS has no formal policy with regards to considering the adverse impacts of investment decision on sustainability. In accordance with the client's risk profile, investment positions are held for a relatively short period of time and hedged thereby minimising any impact on sustainability factors. However, as it is of the utmost importance to SIS that it makes all investment decisions in the best interest of its client, consideration of these adverse impacts may be taken as an additional factor at times for review in making investment decisions (although, it will not automatically outweigh other relevant factors).

SIS will periodically review the appropriateness of developing a formal policy in the future and will update this statement should that occur.