ESG Sustainability Policy

Sustainability-Related Disclosures pursuant to regulation (EU) 2019/2088 (“SFDR”)

Replica SIM SpA Sustainability Risk Policy

According to Art. 2 (22) of Regulation EU 2019/2088 on sustainability-related disclosures for the financial services industry, known as Sustainable Finance Disclosure Regulation or “SFDR”, sustainability risk means “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”. 

Replica SIM SpA (“Replica”) has committed to developing a Sustainability Risk Policy that will describe how Replica will integrate sustainability risk into its investment decision making process. Sustainability risk is currently managed as part of the overall risk management process adopted by Replica. The investment strategies are designed to be diversified and not hold concentrated positions. This serves to mitigate the risk that any specific ESG event or condition will have a material negative impact on the overall value of a Fund. Replica monitors a range of data points to assess investment risks.

For further details on each Fund’s sustainability risk assessment please request a copy of Replica’s Sustainability Risk Policy and/or Fund Prospectuses, by writing an email to

For the purpose of Regulation EU 2019/2088 on sustainability-related disclosures in the financial services sector, the Fund does not promote any Environmental or Social objectives, nor does it have a sustainable investment objective.

No consideration of sustainability adverse impacts

Pursuant to Article 4(2) of the Sustainable Finance Disclosure regulation (SFDR), Replica opts out of the requirement to consider the adverse impacts of its investment decisions on sustainability factors. This approach is applied on the basis that Replica has less than 500 employees and the current size and scale of its investment business is such that it cannot have any meaningful impact on ESG factors. Replica will continue to review its approach and at such point it deems it appropriate, the adverse impacts of its investment decisions on sustainability factors, within the SFDR framework, will be considered.

Remuneration policy

Replica has updated its remuneration policy to meet the requirements of SFDR. Replica’s remuneration policy is designed to ensure that the remuneration of key decision makers is aligned with the management of short and long-term risks, including the oversight and where appropriate the management of sustainability risks in line with SFDR. Replica’s remuneration policy is reviewed periodically or as required by regulations.

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Replica Markets is the trading name of Replica SIM SpA
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