The SFDR and the Taxonomy Regulation require investment fund managers, including Affor Analytics B.V., to provide sustainability disclosures with respect to the funds under management. This section provides for this disclosure with respect to Affor Analytics B.V.

Affor Analytics B.V. does not consider adverse impacts of investment decisions on sustainability factors and does therefore not prepare a so-called annual principal adverse sustainability impact statement (PAI). Affor Analytics B.V. believes that there is currently insufficient reliable data available to determine the potential negative effects of investments in relation to sustainability. Where detailed data is available, it is often expensive to obtain and time-consuming to analyse. Affor Analytics B.V. believes that the costs of including such effects in the investment process do not outweigh the expected benefits. As a consequence, Affor Analytics B.V. does not explicitly take into account the possible negative effects of investments on sustainability factors in the investment process and has no intention to do so in the near future.

Investments by Affor Analytics B.V. are (in principle) made automatically by algorithms via carefully tested trading systems acting based on, including but not limited to, fundamental, technical and sentiment features derived from large datasets which are cleaned and enriched in-house. These systems act on technical and/or fundamental parameters determined from historical tests based on (past) quantitative data. The systems therefore take into account a lot of (historical) data and, according to the data, a wide range of risks is integrated in the algorithms and trading systems. However, there are no specific sustainability risks integrated in the algorithm and trading systems. Integrate such risks would take years to test in order to develop a solid algorithm. Considering this, specific sustainability risks are not taken into account when taking investment decisions.

Under the AIFMD registration regime, Affor Analytics B.V. is not required to adopt a remuneration policy. Given the limited size of the organization, it has not been decided to draw up a specific (voluntary) remuneration policy. Due to the absence of (an obligation to draw up) a remuneration policy, Affor Analytics B.V. is (logically) not able to integrate sustainability risks in such policy.

Date: 03-05-2023