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On this page we describe the sustainable investment policy of Sustainable Dividend Value Fund. The reference is the Sustainable Finance Disclosure Regulation (SFDR). The SFDR is a European regulation that stems from the EU Sustainable Finance Action Plan and will apply from 10 March 2021 to most financial market participants. The objective of the SFDR is to harmonize and make sustainability policy transparent. The Sustainable Dividend Value Fund endorses this objective. The fund supports the sustainability objectives and puts them into practice by integrating sustainability into the investment process. The management therefore not only aspires to a good financial return, but also expressly takes into account the social impact of the investments.

A concept that is central to the SFDR is sustainability risk. It is an environmental, social or governance (ESG) event or condition which, if it occurs, could have an actual or potential adverse effect on the value of the investment. Because sustainability risks, like the other risks mentioned in the information memorandum of the fund, can have an impact on the return on your investments, sustainability risks are part of the investment policy of the Sustainable Dividend Value Fund. When selecting investments, the potential sustainability risks are taken into account in that context.

Besides this specific sustainability risk, sustainability criteria are also an integral part of our investment process. In addition to the importance of the social impact of the investments, we are convinced that companies that score well on ESG criteria perform better in the long term and can therefore offer higher returns at a lower risk. The expectation that ESG investments have a higher expected return is supported by recent studies and Capital Market Assumptions (CMA) of various investment banks.

Selection criteria
When selecting the stocks for our portfolio, we look at both the products or services that a company provides and the way in which these products or services are produced or provided. Each share in the fund has a sustainability score for both the product (Product Score) and the production process (Process Score). The Process Score consists of three sub-scores in the field of ecological policy (Environment Score), social policy (Social Score) and good corporate governance (Governance Score). Companies with a Product Score or Process Score that are too low are not eligible for the fund. In this way, sustainability criteria are inextricably linked to the fund's investment policy.

In addition, the fund excludes companies based on controversial behavior and controversial products (including controversial weapons, tobacco, palm oil and fossil fuels). The fund's reference index, the MSCI Europe Index (Net Total Return in EUR) is a general market index, representing the investment universe, and is not a benchmark for the ESG characteristics promoted by the fund.

We rely on various sources for the information about sustainability. The annual reports of the companies in which the fund invests are important. These reports usually already provide a good insight into the sustainability factors. The impact of the Non-Financial Reporting Directive (NFRD), the Directive with regard to the disclosure of non-financial information, is important here. This European directive obliges large public interest entities (PIE), such as securities issuers, banks and insurers, to include a statement on non-financial information. In it they report on environmental, social and human resources issues, respect for human rights and the fight against corruption and bribery. The European Commission announced in 2020 that this directive will be further tightened. We also speak with the management of the companies in which we invest. We then also test this information from the companies themselves against external sources with sustainability information.

SFDR classification of the fund.

The Sustainable Finance Disclosure Regulation (SFDR) categorizes the universe of available investment funds into three groups:
- Gray (article 6): promotes products that do not have ESG features;
- Light green (article 8): products that promote sustainability and contain many ESG criteria.
- Dark green (article 9): Products that have sustainability as an objective and have the best governance.

Based on the investment policy described above, we classify the Sustainable Dividends Value fund as a 'light green' (article 8) fund. In line with the SFDR, the (performance) objectives for fund management do not contain incentives that could encourage excessive (sustainability) risk-taking. This also means that management does not allocate any additional remuneration in relation to the sustainability objectives.

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