ESG

Buy & Hold SGIIC, SA – Website Disclosures

Responsible and Sustainable Investing

We do not assess Environmental, Social and Governance (“ESG”) Factors that may have investment ramifications, and which may have a material impact on the investment’s long-term financial performance. As a result, information on ESG Factors does not form part of our investment recommendation/decision making process.

Notwithstanding the above, we dedicate a lot of time and effort to find, understand and analyse listed companies, trying to invest in good businesses, managed by honest managers whose interests are aligned with shareholders. We study the financial situation of the company, the quality of its management team, the evolution of its business and its competitive environment, its cash generation, and, of course, its valuation. The objective of Buy & Hold is to invest in companies with an excellent management team, alignment of interests with shareholders, barriers to entry and/or competitive advantages over the competition, high return on invested capital and whose intrinsic value is not reflected in their share price.

Negative and positive screening

We will actively engage with our clients to understand whether they have concerns about specific activities and / or industries in order to maintain such exclusions on an on-going basis.

In such cases, we undertake, to the extent possible, to screen target entities and / or products that promote and provide solutions that are consistent with ESG Factors and shall aim at recommending and / or investing in such on an on-going basis, in so far as applicable.

Exclusions

We will not invest or limitedly invest in certain sectors or companies whose products, services or activities could be considered contrary to the current trends regarding the promotion of ESG criteria based on the following internationally recognized guidelines and principles:

• the UN Global Compact;
• the OECD Guidelines for Multinational Enterprises;
• the United Nations Guiding Principles on Business and Human Rights;
• the Ottawa Convention (international agreement on the prohibition of anti-personnel mines); and
• the Convention on Cluster Munitions.

Principle Adverse Impacts

We do not undertake an assessment of the Principal Adverse Impacts (“PAIs”) of our decisions on ESG Factors. PAIs are those impacts arising from a particular decision taken which we take that will eventually have a negative effect on ESG Factors.

Alignment of Remuneration provisions with sustainability investments

Buy & Hold has a remuneration policy for its employees approved by its Board of Directors, in accordance with current regulations. The remuneration policy is composed of a fixed remuneration, depending on the functional level and responsibility assigned to each employee, and a variable remuneration, linked to the achievement of individual, departmental and company objectives which is determined to be justified following a performance assessment based on quantitative (financial) as well as qualitative (non-financial) criteria. This remuneration policy is in line with rational risk management and does not induce the assumption of risks incompatible with the profile of the funds managed. This remuneration policy is reviewed at least once a year to ensure that it is properly updated where necessary.

Due to this very limited impact on the risk-profile of our clients, as well as the nature of our business, we deem that there is no risk of misalignment with the integration of the sustainability risks, if any, in our investment decision making process.

As such, we believe that our existing structures are sufficient to prevent excessive risk taking in respect of sustainability risks, if any.

Kindly contact relacionconinversores@buyandhold.es for a full copy of our ESG Policy.