Disclosure of

sustainability-related information

Sustainability factors (environmental, social, and governance (ESG)) are understood as environmental, social, and employee matters, as well as issues related to respect for human rights and the fight against corruption and bribery. Sustainability risk refers to an event or situation related to these sustainability factors that, if it occurs, could have a real or potential material negative impact on the value of investments. The relevance and materiality of sustainability risk depends on the investment strategy and asset class.

The Management Company has approved a Sustainability Risk Integration Policy (hereinafter – the Policy), whose main purpose is to define the Management Company's approach to sustainability risk and adverse impacts on sustainability that may arise in managing collective investment undertakings (hereinafter – the Funds), including when making investment decisions. The Policy sets out the procedure for integrating sustainability risks, under which the Management Company evaluates not only financial data but also monitors, analyzes, and takes into account non-financial performance indicators related to sustainability – including environmental and social impact and governance best practices – which may affect not only investment returns but also the performance of companies in both the short and long term.

The integration of sustainability risks into the investment decision-making and execution process involves several methods, which may differ depending on the Fund and asset class, and may be applied either jointly or separately. During the investment evaluation process, methods used include exclusion lists, the integration of sustainability indicators into the analysis of potential investments and the investment management process, as well as active ownership and engagement.

The following sustainability-related risks may negatively impact the value of investments:

• Climate change and natural disasters (e.g., rising sea levels, extreme weather events, floods, heatwaves), which can increase insurance costs or reduce asset value;

• Inefficient use of energy and resources (e.g., high CO₂ emissions or water waste), which can lead to rising operational costs and decreasing investment returns;

• Environmental degradation and pollution (e.g., improper waste management, soil or water contamination), posing reputational and legal risks;

• Transition risk associated with moving to a low-carbon economy due to regulatory, technological, or market changes;

• Social risks related to violations of labor rights, disregard for human rights, or unethical behavior;

• Governance risks stemming from ineffective corporate governance, lack of internal controls, or non-compliance with legal requirements.

For each Fund, these risks manifest differently – their materiality, likelihood, and impact on investment returns depend on the Fund's investment strategy, asset class, sector, and geographic location. The results of sustainability risk assessments and their relevance are disclosed in the specific Fund's prospectus.

The Management Company currently does not consider the principal adverse impact (PAI) of investment decisions on sustainability factors, as defined in Article 4 (1) (b) of the Regulation.

This decision has been made due to the current lack of adequate data availability, quality, and comparability, which are essential for an accurate, well-founded, and consistent assessment of the impact on sustainability factors at the company level.

The Management Company will periodically review this decision, taking into account changing circumstances, including clarity in regulatory requirements, data availability, and the feasibility of conducting a comprehensive assessment of principal adverse impacts.

The Management Company has approved, and is currently implementing, an EU regulation-compliant Remuneration Policy, the aim of which is to ensure that the Management Company’s remuneration policy matches and promotes the reliable and effective management of risks, including, to the extent such is relevant, sustainability risks.

More detailed information can be found here

More detailed information on the integration of sustainability risks into the investment-related decision making process is provided in the Management Company’s approved Sustainability Risk Integration Policy, rules appertaining to specific financial products, and other pre-contractual information documents and periodic reports. All sustainability-related information is published on the Management Company’s website at www.nteram.lt.

To ensure the reliability of information provided in the present Notification, the Management Company intends to update it regularly and to supply the reasons for such revisions and changes.

Sustainability Risk Integration Policy