SFDR Disclosures

WorxInvest Horizon BV (“WorxInvest Horizon” or “WIH”) makes the following disclosures in accordance with the sustainable finance disclosure regulation (“SFDR”) 2019/2088.

Integration of sustainability risk in the investment policies (Article 3 (1))

Environmental, Social and Governance (“ESG”) matters could affect the performance of the investment portfolios managed by WIH and hence are given appropriate consideration in our investment decision-making and portfolio monitoring processes. A sustainability risk means an event or condition that, if it occurs, could cause an actual or potential negative impact on the value of an investment. For alternative investment funds managed by WIH, investment decisions are based on an investment process that includes ESG considerations. This pre-investment process aims to assess both the opportunities and the risks involved with the potential investment, including sustainability risks. The conclusions of this assessment are typically included in a dedicated section in the investment memorandum that is presented to the Investment Committee.

Principal adverse impact of investment decision on sustainability factors (Article 4 (1) (b))

WorxInvest Horizon does not consider principal adverse impacts (“PAIs”) of investment decisions on sustainability factors (i.e. environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters). WIH could not systematically and consistently gather all data on principle adverse impacts at a reasonable cost to investors. This is in part due to the nature of its strategy as a fund-of-fund, and because the underlying (prospective) fund managers generally do not currently report on the PAIs.

Principal adverse impact of investment decision on sustainability factors (Article 5 (1))

As a sub-threshold manager of alternative investment funds, WorxInvest Horizon does not have an obligation to have a formal remuneration policy in accordance with article 40 and following of the Belgian law of 19 April 2014 on alternative entities for collective investments and their managers.