Article 2 – Definitions
For the purposes of Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation – “SFDR”), the following definitions apply:
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Sustainability Risk:
An environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment. -
Sustainable Investment:
An investment in an economic activity that contributes to an environmental objective or a social objective, provided that such investments do not significantly harm any environmental or social objective and that the investee companies follow good governance practices. -
Principal Adverse Impacts (PAIs):
The most significant negative impacts of investment decisions on sustainability factors relating to environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
Article 3 – Sustainability Risk Policy
Manentia Wealth Consulting Group Limited (“MWCG”) integrates sustainability risks into its investment decision-making and advisory processes as part of its broader risk management framework.
Sustainability risks are assessed alongside traditional financial risks when evaluating financial instruments and making investment recommendations. Where relevant, sustainability risks may be considered through qualitative assessments, third-party ESG data sources, and product-level disclosures provided by manufacturers.
Article 4 – Principal Adverse Impacts (PAIs)
At this stage, MWCG does not consider the principal adverse impacts of investment decisions on sustainability factors for the purposes of Article 4 of SFDR.
This position is based on the following considerations:
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The size, nature and scale of MWCG’s activities;
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Reliance on third-party product manufacturers for ESG and sustainability data;
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Limited availability, consistency and comparability of PAI data across products and asset classes.
MWCG reviews this position annually and reassesses whether PAIs should be considered as data availability, regulatory guidance and market practices evolve.
Article 5 – Remuneration Policy and Sustainability Risks
MWCG’s remuneration framework is designed to promote sound and effective risk management and does not encourage excessive risk-taking, including sustainability-related risks.
Sustainability risks are integrated into remuneration governance through the following principles:
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Remuneration is not directly linked to the sale or promotion of specific financial products, including products with sustainability features;
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Incentive structures do not reward mis-selling or the prioritisation of products inconsistent with clients’ investment objectives or sustainability preferences;
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Variable remuneration considerations take into account compliance with regulatory obligations, internal policies and client-centric outcomes.
Article 10 – Product-Level Disclosures
Where MWCG advises on or distributes financial products that promote environmental or social characteristics or have sustainable investment objectives, product-level disclosures are made available by the respective product manufacturers.
Clients are encouraged to review the relevant pre-contractual disclosures and product documentation before making any investment decision.
Governance and Oversight
The Board of Directors and senior management oversee MWCG’s sustainability-related disclosures and ensure that they remain accurate, clear and up to date.
These disclosures are reviewed:
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At least annually; and
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Whenever there is a material change to regulatory requirements or business practices.
Contact
Questions about these disclosures: DPO@mwcgroup.ch.
Last updated on 23rd December 2025 (Reviewed Annually)