Regulation
Numisma Capital Ltd is regulated by the Cyprus Securities and Exchange Commission (CIF licence no. 122/10). The company operates in accordance with the Markets in Financial Instruments Directive (MiFID) of the European Union.
The company is also registered with the following:
- - BaFin (Bundesanstalt für Finanzdienstleistungsaufsicht), Germany under registration number 133282
- - CONSOB (Commissione Nazionale per la Società e la Borsa), Italy under registration number 3739
- - ACP (Autorité de Contró Prudentiel), France under registration number 74590
- - CNMV (Comisión Nacional del Mercado de Valores), Spain under registration number 3498
- - AFM (Autoriteit Financiële Markten), Netherlands
- - FI (Finansinspektionen), Sweden
- - FIN (Finanssivalvonta Finansinspektionen), Finland
Sustainable Finance Disclosures
Version 1
31-12-2022
1. Introduction
Numisma Capital Ltd (the “Company”) is a limited liability company with share capital, incorporated in accordance with the Laws of the Republic (registration number HE258965). The Company is regulated as an under the threshold alternative investment fund management company (“AIFM”) by the Cyprus Securities and Exchange Commission (“CySEC”) with license number CIF 122/10 and as a Cyprus Investment Firm offering the services of Portfolio Management and Investment Advice. As the Sustainable Finance Disclosure Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (the “SFDR”) been entered into force, by this policy and other related policies/procedures and disclosures the Company intends to provide a definition of relevant factors and controls relating to sustainability risks.
The SFDR requires financial market participants and Financial Advisers to disclose additional information on the integration of sustainability risks and potential adverse sustainability impacts on an entity level. Towards this the Company is required to publish:
• The Sustainability Risks Policy as per Article 3 of the SFDR,
• Any information on Adverse Sustainability Impacts as per Article 4 of the SFDR, and
• The Remuneration policy as per Article 5 of the SFDR.
As per the services licensed to offer the Company is considered as per SFDR as ‘Market Participant’ and ‘Financial Adviser’.
2. Sustainability risks policy
The Company in its capacity as ‘Financial Adviser’ and as ‘Market Participant’ (under the threshold AIFM’ does not consider any specific ESG principles for the services offered nor does any of the AIFM’s funds under management. Numisma Capital Limited considers ESG matters to be important and intends at a later stage to consider the gradual integration of any considerations and their implications within the investment decision making process. As per above, Numisma Capital Limited will implement certain processes to integrate the potential impact of sustainability risks directly or via identified investment risks such as market, operational, liquidity, credit, or reputational risks.
The Company in its capacity as ‘Market Participant’ offering the service of Portfolio Management acknowledges the potential impacts that sustainability risks can impose on the portfolios managed and considers the approach to integrate the risks arising from sustainability issues described in this policy. Before any investment decisions are taken on behalf of the clients that the Company manages, the Company will have to complete a process for the identification of the material risks associated with each proposed investment, including sustainability risks.
More information on Company’s approach to integrate sustainability risks into the investment decision making process (pre-trade assessment) can be found in the Sustainability Risk Policy which has been uploaded separately on the Company’s website. The Company fulfils its risk management duties internally towards the portfolios managed an Investment Firm by including sustainability risks in its post-trade risk assessments.
3. No consideration of adverse impacts of investment decisions on sustainability factors
As per Article 12 of Commission Delegated Regulation (EU) 2022/1288, Numisma Capital Ltd, in its capacity as a Financial Market Participant and ‘ Financial Adviser’ as defined in Regulation, at the moment does not consider principal adverse impacts of investment decisions on sustainability factors. The main reason is actually the lack of information and data which prevents a proper like-to-like comparison between investments in terms of the ESG factors and because this limits the range of available investments under consideration and thus reduces diversification. The Company may reassess its consideration in the future in regard to adverse impacts on environmental, social and employee matters. If at any time this changes a disclosure shall be made available on our website.
4. Integration of sustainability risks in the remuneration policies
Numisma Capital Limited integrates sustainability risks into its remuneration Policy, in its capacity as a financial market participant and as Financial Adviser. The remuneration practices followed by Numisma Capital Limited do not encourage risk-taking with respect to sustainability risks.
5. Review and monitoring
The Company will monitor and review the SFDR disclosures and the Policy on an annual basis and will proceed to changes where needed. Any update will be made in accordance with the regulations applicable and will be subject to the approval of the Company’s Board of Directors.
Legal
Company Documents
- Internal Procedures Manual English
- Risk Management Disclaimer in English
- Operation license in Greek / English
- Investor Compensation Fund in Greek / English
- Information Script in English
- Policy to act in the Best Interest of Clients in English
- Conflict of Interest Policy English
- Complaints Form English
- Remuneration Policy English
- Complaints Handling Procedure English
- SRD II - Shareholder Engagement Policy Statement English
- Sustainability Risks Policy English
- Annual Remuneration Report 2023 English
- Key Information Documents for the following AlFLNPs under management:
Governing Law
