As permitted under Article 4 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (the “SFDR”), Harrington Cooper Asset Management Limited (‘HCAML’) does not consider adverse impacts of investment decisions on sustainability factors on the basis that it is not a financial market participant that is required to do so given that HCAML does not have on its balance sheet an average number of employees exceeding 500 during the financial year. HCAML may choose at a later date to publish and maintain on its website the consideration of principal adverse impacts of investment decisions on sustainability factors. HCAML will review its approach to considering the principal adverse impacts of investment decisions on sustainability factors within the meaning of SFDR on a periodic basis.
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