ESG Investment Disclosure
Governance of Climate-related Risks
The Company’s governance structure consists of is oversight of climate-related risks at the Board of Directors (“BOD”) level and the implementation of climate-related risk management policies and practices at the management level.
The Board or ESG Committee is responsible for overseeing the incorporation of climate-related risks into the investment management and risk management process of the Fund. The board or ESG Committee reviews and approves any required updates to the Risk Management Policy, which provides a framework for managing key risks, including climate-related risks at least annually. In particular, the Board receives annual updates at least from management to oversee progress and stay informed on climate-related risk management.
Management is accountable for the incorporation of climate-related risks into the investment management, risk management and disclosure process. In particular, the responsibilities for managing climate-related risks have been assigned to the ESG Committee that reports to the Board periodically. Management (through ESG Committee) will monitor the status and progress of efforts to manage climate-related risks.
Identification and Assessment of Climate-related Risks
The Company identifies climate-related risks by reviewing the Fund(s)’s investment strategies and determining if climate-related risks are relevant. For example, for funds that track a specific index (specifically pure passive funds tracking a non-sustainable reference benchmark), climate-related risks are not relevant due to the passive nature of the strategy. In particular, the Company reviews for relevance of climate-related risks at least annually by completing a relevance assessment based on strategies for which climate-related risks are typically considered relevant or irrelevant, which is reviewed by the ESG Committee. The Company has determined climate-related risks are relevant.
The Company conducts a further assessment by using a qualitative method to determine if climate-related risks are material for the Fund(s) at least annually by completing a materiality assessment based on proportion of holdings in industries or geographic areas subject to high climate-related risks, which is reviewed by the ESG Committee company has determined that climate-related risks are not material.
The method of assessing relevance and materiality of climate-related risks require subjective judgements and may include consideration of third-party data that is incomplete or inaccurate. The assessment methodology may change or evolve over time. Relevance and materiality have been assessed based on certain qualitative and quantitative factors concerning the strategy as well as industry practices and subjective estimates, which may change. Any such changes may affect the assessment conclusions and previous assessments may no longer remain valid. There can be no guarantee that the Company will correctly identify and assess the impact of climate-related risks associated with its asset management activity.
Remark: The above disclosure may be translated into Chinese language but in the event of any conflict arising the English version shall prevail.