What is MiFID?
MiFID (Markets in Financial Instruments Directive) is a European regulation that applies to all E.A.Fs (Financial Advice Companies). Expert Timing System International, E.A.F., S.L. is a registered and supervised E.A.F by the National Stock Market Commission (official registration number: 33).
What is MiFID for?
It is intended to protect retail clients in the security markets. The majority of our clients are not retail ones, but the European Union compels us to inform any visitor of our website about retail client's rights.
This Directive was adopted to protect such investors. The purpose is to inform retail clients about how much the services of the EAFs cost.
Information on the consideration of adverse sustainability events
In accordance with the provisions of article 4 of the EU Disclosure Regulation, it is hereby informed that EXPERT TIMING SYSTEMS INTERNATIONAL, EAF, S.L. (hereinafter "the Entity") does not take into account the adverse impact of investment decisions on sustainability factors (PIAS), as it does not currently have detailed information or due diligence policy in relation to such adverse impacts.
Consistency of remuneration policies
The Entity considers that its remuneration policy is consistent with its approach to integrating sustainability risks into the investment decision-making process.
Sustainability risks are considered, among other potentially relevant risk factors, when making investment decisions and failure to take into account any of the relevant risks could have an adverse impact on investment performance.
In general, the Entity's remuneration policy is based on fixed and variable remuneration. Variable remuneration is determined on a discretionary basis and is strongly linked to the performance of individual employees and the overall financial performance of the Entity. Under this system, any failure to consider sustainability risks with an adverse impact on investment performance would be reflected in the level of overall variable remuneration awarded to staff. In addition, in this case, adverse performance is likely to impact variable remuneration at the individual level.
Sustainability risk policies and integration
Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainable-related disclosures in the financial services, requires the Entity to make certain disclosures on its website, including information on the “EAF's” (financial advisory firm) policies on the integration of sustainability risks into its investment decision-making process, its approach to adverse sustainability impacts, and the consistency of its remuneration policies with the integration of sustainability risks.
Its objective is to provide end-investors with information on the integration of sustainability risks carried out by institutions.
In this regard, it should be noted that as part of the evaluation of investments, the Entity, through its advisory team, will consider, if appropriate, the risks relevant to the sustainability of potential investments.
The Entity seeks to recognise, evaluate and appropriately weigh all relevant risk factors when making investment recommendations to its clients. Thus, sustainability risks are only one of several risk aspects considered as part of investment decision-making. Other risk factors considered could include (but are not limited to): market, liquidity and counterparty risks. ESG (environmental, social and governance) factors and risks are therefore taken into account in the investment decision-making process as an additional tool providing further information on current and potential non-financial risks of investments. Therefore, it should be understood in conjunction with the traditional and non-exclusive analysis of "sustainable investment".
While the Entity believes that sustainability risks could have an impact, positive or negative, on client portfolio returns, these impacts are not material given the management model followed within the Company.
Due to all, the Entity does not currently have specific sustainability risk policies, or other similar type of ESG policies, for its investments.
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