SMT Fund Services (Ireland) Limited (the “Management Company”) is authorised by the Central Bank of Ireland to provide UCITS Management Company/AIFM services to a range of UCITS/AIFs domiciled in, but not limited to, Ireland.

As per Regulation (EU) 2019/2088 (“SFDR”), the Management Company is defined as a “financial market participant”.

Statement on the Transparency of Sustainability Risk Policies

Per Article 3 of SFDR, a financial market participant is required to” publish on their websites information about their policies on the integration of sustainability risks in their investment decision‐ making process.”

The Management Company have adopted this statement to describe the approach taken to demonstrate compliance with Article 3 of SFDR.

For the purpose of this statement:
“Sustainability risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.

Delegation and Integration of Sustainability Risks
The Management Company does not carry out any discretionary investment management in respect of any of the funds under management but delegates discretionary investment management to suitably qualified third party investment managers (the “Investment Managers”). The degree to which sustainability risks are, or are not, integrated into the investment decision making shall be detailed within the pre-contractual documents of each Fund in accordance with Article 6 of SFDR.

The Management Company has enhanced its due diligence processes to ensure that disclosures made in pre-contractual documents shall be consistent with the investment objectives of the funds, investor profiles and the infrastructure implemented at each Investment Manager appointed to a Fund.

Where sustainability risks are integrated into investment decision making/research in respect of a Fund the Management Company will periodically assess the adequacy of ESG/SFDR integration at Investment Manager through requests for information to evidence the results of such integration, the issuance of due diligence questionnaires, onsite due diligence visits etc.

The Management Company have enhanced the existing risk management frameworks to account for integration of sustainability risks. Further, the risk management function shall oversee the integration of sustainability risks by the Investment Managers on an ex-post basis.

Should the Management Company determine that either the infrastructure in place at the Investment Manager is not sufficient, or the Fund is not being managed in line with the disclosure of sustainability risks in its pre-contractual documents, the Management Company will take steps to ensure corrective action is taken.

Statement on the Transparency of Adverse Sustainability Impacts at Entity Level
Per Article 4 of SFDR a “financial market participant”, where the principal adverse impacts (“PAI”) of investment decisions are considered, is required to publish and maintain on its website a “statement on due diligence policies with respect to those impacts, taking due account of their size, the nature and scale of their activities and the types of financial products they make available”. This Statement has been developed in accordance with the provisions of Article 4, while also taking into consideration Article 7 of SFDR on the transparency of PAI at product level.

The Management Company does not consider PAI of investment decisions on sustainability factors on the basis that it is not a financial market participant that is required to do so given it does not have in excess of 500 employees during the financial year. The Management Company will review its approach to considering the PAI of investment decisions on sustainability factors within the meaning of SFDR on a periodic basis.

Delegation and Consideration of PAI (Article 4 and Article 7 of SFDR)
“Investment decisions” as defined under SFDR are delegated to the Investment Managers, subject to the Management Companies’ ongoing oversight.

Further, the Funds follow a number of different investment strategies with varying consideration of environmental, social and governance (ESG) and sustainability factors. As such, some of the Investment Managers may consider PAI in respect of the Funds for which they are appointed while other Investment Managers may not. Due to the different strategies and nature of the Funds under management, the Management Company has determined it prudent to allow for both eventualities in this Article 4 SFDR Statement taking into account Article 7 of SFDR.

Dual Approach

1. Should the Investment Managers wish to consider PAI in respect of the Funds to which they are appointed in line with Article 7 of SFDR, the Management Company shall ensure that:

  • The Investment Manager has the appropriate infrastructure in place to report on PAI on an ongoing basis
  • Where PAI are to be considered in respect of a Fund, the appropriate disclosures are made in the pre-contractual documents in line with SFDR by 31 December 2022
  • The list of Funds for which PAI are considered is available on request
  • The processes, systems and procedures in place to consider and report on PAI in respect of each Fund shall remain subject to the Management Company periodic due diligence
  • The  Investment  Manager  also  publishes  appropriate  disclosures  on  its  website  in accordance with Article 4(1) and (2) of SFDR, while also considering the associated Regulatory Technical Standards, in respect of the Funds
  • The periodic reports of the Funds contain sufficient and appropriate information as to the assessment of PAI

2. Where PAI are not considered in respect of a Fund, the Management Company shall ensure appropriate disclosures are contained within the relevant pre-contractual docum For further information as to why PAI are not considered in respect of a particular Fund, please refer to the Prospectus/Supplement of that Fund. The list of Funds for which PAI are not considered is available on request.

SFDR Article 10 Website Disclosures

In line with Article 10 of SFDR, financial market participants are required to “publish and maintain on their websites the following information for each financial product referred to in Article 8(1) and Article 9(1), (2) and (3):

  • (a) a description of the environmental or social characteristics or the sustainable investment objective;
  • (b) information on the methodologies used to assess, measure and monitor the environmental or social characteristics or the impact of the sustainable investments selected for the financial product,  including  its data  sources, screening criteria  for the underlying assets  and the relevant sustainability indicators used to measure the environmental or social characteristics or the overall sustainable impact of the financial product;
  • (c) the information referred to in Articles 8 and 9;
  • (d) the information referred to in Article 11.”

The purpose of this Statement is to disclose the location of the above information in respect of the
Funds which fall within the meaning of Article 8 or Article 9 for the purposes of SFDR.


Article 8 Funds

The following Funds  fall within the meaning of Article 8 for the purposes of  SFDR, for further information in respect of same, please see below.

Fund Name Website
Japan Small Cap Fund
Japan Small Cap II Fund
Japan Quality Growth Fund


Article 9 Funds

None of the Funds fall within the meaning of Article 9 for the purposes of SFDR.


Review and updating of this policy
The Policy adopted herein will be reviewed on at least an annual basis by the Management Company to ensure that the provisions are suitable and reflect accepted best practice.  The Policy will also be provided to the Board of Directors of the Management Company for their review and approval on this basis.

The Management Company will also use its reasonable endeavours to ensure that the Policy remains appropriate to  the structure  and size of the Management  Company and the  nature, scale and complexity of the Management Company’s underlying Funds under management.