SFDR

Website Disclosure Statement

SFDR

No consideration of sustainability adverse impacts

Optimum Complexity Ltd (“Optimum”) does not currently comply with the overall SFDR disclosure framework. This approach is applied on the basis that Optimum has less than 500 employees and the current scale of its investment business is such that it cannot have any meaningful impact on ESG themes.

Notwithstanding this, Optimum does consider sustainability risk within its investment process. With sustainability an objective within its complexity-based investment strategies, Optimum promotes environmental and social characteristics to the extent that it applies some exclusion criteria and promotes some aspects of sustainability, such as sector preferences in its Equities business.