by Broker Consulting, a.s., with registered office at Jiráskovo nám. 2, 326 00 Plzeň, ID No.: 252 21 736, registered in the Commercial Register administered by the Regional Court in Plzeň, Section B, File 1121 (hereinafter only referred to as the Company).
This Statement on Principal Adverse Impacts on Sustainability is being published in compliance with Regulation (EU) 2019/2088 of 27 November 2019, on the disclosure of information related to sustainability in the financial services sector (Sustainable Finance Disclosure Regulation, hereinafter only referred to as “SFDR”), as well as in compliance with the Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022, supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying the details of the content and presentation of information in relation to the principle of “do no significant harm”, specifying the content, methodologies and presentation of information in relation to sustainability indicators and adverse sustainability impacts, and the content and presentation of the information in relation to the promotion of environmental or social characteristics and sustainable investment objectives in pre-contractual documents, on websites and in periodic reports (hereinafter only referred to as “RTS”).
This Statement on Principal Adverse Impacts on Sustainability Factors includes both the “Statement on Principal Adverse Impacts of Insurance Counselling on Sustainability Factors” and the “Statement on Principal Adverse Impacts of Investment Counselling on Sustainability Factors” (hereinafter only referred to as the “Statement”).
In this Statement, the Company is disclosing how it takes into consideration the principal adverse impacts of investment and insurance counselling on sustainability factors within the framework of its business activity as an investment and insurance intermediary.
As part of its business activity, the Company distributes investment and insurance-based investment products, while simultaneously serving as a financial consultant in accordance with the SFDR.
The Company provides its clients with transparent information about any sustainability risks related to the individual investment products or the underlying assets of insurance-based investment products. The available investment products are assessed in terms of sustainability, and while considering the selection of a suitable investment or insurance-based investment product, the client is provided with counselling, which takes into account the client’s preferences concerning sustainability. In this respect, principal adverse impacts on sustainability factors are being taken into consideration during investment and insurance counselling. As part of counselling, the primary focus of assessment is the client’s attitude towards investment risk; assessed subsequently and consistent with it are then the client’s preferences related to the sustainability of the investment or insurance-based investment products. The client is provided with information on principal adverse impacts on sustainability factors of the recommended products, in line with how they are currently made public.
The principal adverse impacts on sustainability factors are present in different areas, such as especially the following factors:
• Climate/environmental;
• Social and occupational;
• Respect for human rights, or
• Fight against corruption and bribery.
The extent and manner of consideration of adverse impacts associated with investment or insurance counselling is determined by many factors; currently, the most important one being the availability of the necessary data on principal adverse impacts on sustainability factors disclosed by financial market participants within the intention of SFDR and their subsequent processing.
As part of its counselling activity in the insurance and investment sector, the company utilizes information disclosed by financial market participants within the meaning of the RTS regulation, in particular the “Statement of financial market participants that they consider principal adverse impacts of their investment decisions on sustainability factors”, or alternately the “Statement of financial market participants that they do not consider principal adverse impacts of their investment decisions on sustainability factors”, as they become available, i. e. information about whether principal adverse impacts on sustainability factors are being considered, including the specific consideration, indicators utilized for the identification and assessment of the principal adverse impacts on sustainability factors, objectives for the prevention or reduction of the principal adverse impacts on sustainability factors, or the methodology for the selection of the indicators of the principal adverse impacts on sustainability factors.
Concurrently, through its individual financial consultants, the Company processes and provides its clients with information disclosed by financial market participants related to principal impacts on sustainability factors within the meaning of pre-contractual disclosure of product information, which includes information about the promotion of environmental or social characteristics, objectives of sustainable investments, financial products with investment opportunities, and furthermore in accordance with information about the products published by the financial market participants on their websites pursuant to the RTS regulation. The Company also familiarizes itself with and passes on information disclosed by financial market participants in periodic reports pursuant to the RTS regulation.
The company currently does not rank or select products based on a specific methodology of the indicators of principal adverse impacts on sustainability factors, or the criteria or threshold values based on principal adverse impacts on sustainability factors, even in association with information as it is being gradually disclosed and processed by the financial market participants, as well as with issues of principal adverse impacts on sustainability factors from the standpoint of investment decisions, and investment and insurance counselling as they are being incorporated. The Company provides investment and insurance counselling at the level of the individual Company financial consultants, therefore the proposed investment and insurance-based investment products are in line with the client’s needs and requirements, their preferences associated with sustainability and their specifics, the available information disclosed by market participants, and an assessment of all of the aforementioned factors.
This Statement constitutes its first version (22/01).
On 9 December 2022