Sustainable Finance Disclosure Regulation (“SFDR”)

CCGM Pension Administrators Ltd ("CCGM") is a Financial Market Participant (“FMP”) under the SFDR. In accordance with the SFDR requirements CCGM, as a Retirement Scheme Administrator ("RSA") and Trustee of the Lifetime Occupational Pension Scheme and Lifetime Private Pension Scheme (“The Schemes”), is required to provide disclosures on how it considers sustainability risks and the impact of Environmental, Social and Corporate Governance ("ESG").


Dated March 2023



Investment Manager: The entity appointed by the Retirement Scheme Administrator to carry out the services of managing the investments held in the Trust on behalf of the Members and who meets the relevant criteria stipulated in Malta Pension Rules relevant to Personal Retirement Schemes;
Member: A Member of the Scheme;
Sustainability Risks: 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 the investment.
Sustainability Factors: are environmental, social and employee matters, respect for human rights, anti‐ corruption and anti‐bribery matters.
Sustainable Investment: An investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators on the use of energy, renewable energy, raw materials, water and land, on the production of waste, and greenhouse gas emissions, or on its impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality or that fosters social cohesion, social integration and labour relations, or an investment in human capital or economically or socially disadvantaged communities, provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance

Statement on the integration of Sustainability Risks

The Schemes are managed by the appointed Investment Manager in accordance with the investment strategies and within the parameters of the applicable investment restrictions, as set out in each Scheme Particulars. The Investment Manager integrates sustainability risks and opportunities into its research, analysis and investment decision-making processes in respect of ESG, where applicable. The ESG Policy forms an integral part of its investment process and seeks to mitigate ESG and sustainability risks by ensuring that the Investment Manager invests in companies or assets that are operated in an environmentally responsible manner, with respect for human rights and labour rights and providing good, healthy and safe working conditions and promote good governance conduct, always to the extent applicable and appropriate. Where applicable, consideration of potential ESG and sustainability risks related to a company or asset is integrated in the Investment Manager’s investment process, from transaction sourcing and selection to approvals and execution.
Potential risks are further identified in the due diligence process, by means of screening for ESG controversies or further ESG analysis as warranted in context of the specific investments and addressed for each investment on a case-by-case basis pursuant to the Investment Manager’s risk management framework and ESG Policy.
While ESG and sustainability risks will be integrated in the investment decision process, no one aspect, such as ESG ratings, would prevent the Investment Manager from making any investment since investment decisions will prioritise, and remain consistent with, the investment strategies and investment restrictions as set out in the Scheme Particulars.

No consideration of principal adverse impacts of investment decisions on sustainability factors

The SFDR requires disclosure as to whether adverse impacts of investment decisions are considered.
CCGM’s position is that it does not consider the adverse impacts of investment decisions on sustainability factors in respect of the Schemes and the strategies, as explained below.
The Schemes are managed by the appointed Investment Manager, meaning that investment decisions are taken by the Investment Manager in accordance with the investment strategies and investment restrictions of the Schemes. The investment strategies and restrictions are set out in the Scheme Particulars, which are accessible on the CCGM website. The Investment Manager of the Schemes does not consider adverse impacts of its investment decisions for the following reasons:

  • The investment process takes into account the very defined nature of the investment strategies and investment restrictions which significantly limit the type of investment that the Schemes may be invested in as this is deemed to be in the best interest of the Scheme and its Members.
  • In view of the current scale of the Schemes, the Investment Manager prioritises the investment strategies of the Schemes, without further limitations being posed by adverse impact considerations.
  • Any considerations made towards adverse impacts would require the availability and consistency of data, however there may be presently still insufficient data reporting. Thus, it is currently not deemed prudent or practicable to incorporate considerations towards adverse impacts of the investment decisions.

The Investment Manager will consider application of considerations of adverse impacts of investment decisions in the future upon assessment of the Schemes’ size and investment strategies, should such size be deemed to be suitable for, and the investment strategies in future to allow, consideration towards such adverse impacts of its investment decisions.
The Investment Manager will evaluate whether to consider adverse impacts in future also on the basis of the availability of data, provided such data is adequate to enable inclusion of adverse impact considerations in its investment decisions.
The current position of the Investment Manager is that should a decision to consider adverse impacts be taken in future, under circumstances which permit so, these would likely be based on one or more indicators for Social and Employee, Respect for human rights, Anti-corruption and Anti-bribery matters

Remuneration Policy

The SFDR requires the RSA to include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks.
CCGM has a fixed remuneration strategy unless it is justified following a performance assessment based on quantitative and qualitative criteria on the entity and personal level. In this regard, CCGM views its remuneration structure to be consistent with the integration of sustainability risks.