Sustainability & ESG Policy

1. Introduction

Xborder Partners Wealth — Empresa de Investimento, S.A. (“Xborder”) is an investment firm authorised and supervised by the Comissão do Mercado de Valores Mobiliários (CMVM), providing investment advice and reception and transmission of orders.

Xborder is committed to conducting its business responsibly. This page sets out Xborder’s approach to sustainability risks and explains Xborder’s position in relation to the consideration of principal adverse impacts of investment decisions on sustainability factors, in accordance with applicable EU legislation.

2. Legal Framework

This Policy is published in accordance with:

Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”), in particular Articles 3, 4 and 5; and
Commission Delegated Regulation (EU) 2017/565, as amended by Commission Delegated Regulation (EU) 2021/1253, which requires investment firms to integrate sustainability factors, risks, and preferences into their organisational requirements and conduct of business obligations under MiFID II.

3. Integration of Sustainability Risks — Article 3 SFDR

What is a sustainability risk?

A sustainability risk means 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. Sustainability risks may include, among others, risks arising from climate change, environmental degradation, social disruption, or failures of corporate governance.

How does Xborder integrate sustainability risks?

Xborder integrates sustainability risks into its investment advice process on a best-efforts basis, to the extent that information on such risks is reasonably available in respect of the financial instruments it advises upon. Where relevant sustainability risk information is available, Xborder’s advisers will take it into account as part of the overall risk assessment conducted in connection with the suitability of a recommended instrument for a given client.

Xborder does not, however, currently operate a dedicated ESG screening or scoring methodology, nor does it apply binding ESG exclusion criteria to the financial instruments it may recommend.

4. Principal Adverse Impacts — Article 4 SFDR

Article 4 of SFDR requires financial market participants and financial advisers to publish information on whether they consider the principal adverse impacts (“PAI”) of their investment decisions or advice on sustainability factors (i.e., environmental, social, employee, human rights, anti-corruption and anti-bribery matters).

Xborder has assessed the nature and scale of its activities and has determined that, at this stage, it does not consider principal adverse impacts of investment advice on sustainability factors within the meaning of Article 4(1)(b) of SFDR.

This decision reflects the following considerations:

Xborder is a small investment firm, limited in scope to investment advice and the reception and transmission of orders;
Xborder does not manage assets, operate investment funds, or make discretionary investment decisions on behalf of clients;
The data and methodologies required to assess PAI in a meaningful and consistent manner across the range of financial instruments Xborder may advise upon are not yet sufficiently available or standardised for a firm of Xborder’s size and profile; and
The administrative and operational burden of full PAI compliance would be disproportionate to the nature and scale of Xborder’s activities at this stage.

Xborder will keep this position under review as its activities develop and as the availability of PAI-related data improves. Should Xborder determine in the future that it is appropriate or required to consider PAI, this Policy will be updated accordingly.

5. Remuneration Policy and Sustainability Risks — Article 5 SFDR

In accordance with Article 5 of SFDR, Xborder confirms that its remuneration policy is consistent with the integration of sustainability risks as described in this Policy. In particular, Xborder’s remuneration structure does not incentivise the taking of excessive sustainability risks and is designed to support conduct that is in the long-term interests of clients.

6. Sustainability Preferences under MiFID II

Commission Delegated Regulation (EU) 2021/1253 amended Delegated Regulation (EU) 2017/565 to require investment firms providing investment advice to take into account clients’ sustainability preferences as part of the suitability assessment process.

Xborder collects information on clients’ sustainability preferences as part of its client suitability questionnaire, in accordance with Article 54 of Delegated Regulation (EU) 2017/565 as amended. However, given the current limitations in the availability of standardised sustainability-related product data, Xborder will apply reasonable efforts to match client sustainability preferences with available financial instruments where such information is disclosed by product manufacturers.

Where no financial instrument meeting a client’s stated sustainability preferences is available or suitable in all other respects, Xborder will explain this to the client and, with the client’s agreement, may recommend an instrument that does not fully meet those preferences but is otherwise suitable, in accordance with applicable guidance from ESMA.

7. No Sustainable Investment Objective

Xborder does not promote environmental or social characteristics, nor does it pursue a sustainable investment objective, within the meaning of Articles 8 or 9 of SFDR, in the context of its investment advice activity. The financial instruments Xborder may recommend are not selected or screened on the basis of binding ESG criteria.

8. Review

This Policy will be reviewed at least annually and updated as necessary to reflect changes in Xborder’s business activities, applicable regulatory requirements, or the availability of sustainability-related data and methodologies. Any material changes will be published on this website.