Sustainable Finance Disclosure Regulation (SFDR)

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The World Markets Umbrella Fund plc (the “Company” or “Fund”) is required to provide investors with certain disclosures required under the SFDR. These disclosures and new definitions as set out below are also included in Addendum No.1 to the Prospectus dated 30 September 2019.


SFDR“, Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector, as amended and as may be further amended.

Sustainability Factors“, as defined in the SFDR, means environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

Sustainability Risk“, an environmental, social or governance event or condition that, if it occurs, could cause a negative material impact on the value of an Investment.”

Principal Adverse Impacts

As a financial market participant, the SFDR requires the Company to make a “comply or explain” decision whether to consider the principal adverse impacts (“PAIs”) of its investment decisions on Sustainability Factors in the manner prescribed under Article 4(1)(a) of the SFDR.

The Company, being a company which has less than 500 employees and which is not a parent undertaking of a group with 500 or more employees, is not, in accordance with the SFDR, required to consider the PAIs of investment decisions on Sustainability Factors.

The Company takes account of Sustainability Risk in the investment decision making process applied to the Fund’s Investments, but has determined not to consider the PAI of investment decisions on Sustainability Factors.

This decision has been made on the basis that the Fund does not have sustainable investment as its investment objective nor has its investment strategy been designed in a way intended specifically to promote any environmental or social objectives.

Sustainability Risks

As a financial market participant, the SFDR obliges the Company to integrate into its investment decisions consideration of Sustainability Risks. As the Company has delegated investment management of the Fund to the Investment Manager, the Company will in practice need to rely upon the investment decision-making processes of the Investment Manager in order to give effect to the foregoing.

The Company through the Investment Manager integrates consideration of Sustainability Risks into the due diligence it undertakes as part of its investment decision processes.

Due to the nature of the Fund’s investment strategy, the Investment Manager does not screen out potential investments based on Sustainability Risks. Further, the Investment Manager does not invest in or divest specific assets based on Sustainability Risks as the Investment Manager’s key objective in managing the Fund is to seek to achieve superior investment performance.

Nonetheless, the Investment Manager’s due diligence with managers of the closed end funds in which the Fund invests involves discussion of Sustainability Risks where relevant with a view to encouraging better disclosure by the closed end fund managers about the ESG characteristics of their strategies.

The likely impact of Sustainability Risks on the returns of the Fund has been assessed by the Investment Manager and has been determined to be low. However, Sustainability Risk is an evolving, multi-faceted and multi-point-impact risk category and there can therefore be no guarantee that this will remain the case throughout the lifetime of the Fund.