Sustainability

A Company's approach to Sustainability

Aquarium Investments IPAS (hereinafter – the Company) gradually integrates environmental, social, and governance (ESG, hereinafter also referred to as sustainability) risk factors into the Company’s operations, processes, investment decision-making, and investment analysis, taking into account the availability of information and data, as well as clients’ expressed preferences regarding sustainability.

The Company has established sustainability guiding principles based on its strategic objectives, which include:

• Corporate Governance: to promote transparency, integrity and responsible decision-making throughout the Company's operations, ensuring consistent practices and ethical behavior towards all.
• Social responsibility: with the aim of promoting a diverse and inclusive working environment, ensuring that every employee is valued and free from any form of discrimination.
• Ethical and compliant business: with the aim of ensuring ethical, law-abiding and compliant business by respecting and implementing high standards in all aspects of its operations.
• The suitability and appropriateness of investment decisions: with the aim of promoting the provision of appropriate, relevant, and transparent information to Clients, enabling them to make an informed choice that aligns with their values and investment objectives.
• Training and development: with the aim of developing and ensuring that staff understand ESG and its drivers and implementation.

The Company intends to ensure a sustainable governance structure and key responsibilities in all areas and levels of its operations, promoting transparency and integration of sustainability factors in the Company's activities.

Sustainability risks and the integration of sustainability factors in investment services

Sustainability risks are events or conditions arising in the environmental, social or governance spheres, the occurrence of which may have an actual or potentially significant negative impact on the value of an investment.

Sustainability risk factors can have a significant impact on investment volatility, liquidity and can cause a decline in the value of investments. Negative impacts can arise from both direct or physical sustainability events or conditions (e.g. extreme climate change leading to flooding or prolonged droughts) and events and conditions associated with the transition to sustainability (e.g. changes in climate and environmental policies, technological progress or changes in market sentiment and preferences). Sustainability risks may contribute to other pre-existing investment risks, including but not limited to credit risk, operational risk, market risk, liquidity risk, legal risk and reputational risk.

For the analysis of sustainability factors and the assessment of risks, the Company intends to use data provided by international rating and information agencies and other external data providers and information already available to the Company.

The Company has determined that the employee providing client advice, as well as the managers of individual client portfolios, will be responsible for the integration of sustainability factors into the investment service.

In implementing the integration of sustainability factors into investment decision-making, it is intended to apply a "best-in-class" approach (investing in financial products/companies that perform better on sustainability factors than other similar financial products/companies), as well as an exclusion approach (setting criteria for refraining from investing in a particular financial product/company).

The Company discloses that it does not include sustainability risks in its remuneration policy.

When making investment decisions, adverse impacts on sustainability factors are not taken into account.

Aquarium Investments IPAS does not take into account the adverse impacts of investment decisions on sustainability factors when making investment decisions.

The Company still faces challenges in the availability of sustainability data, as a result of which no systematic approach to assessing the negative impact of investment decisions on sustainability factors has yet been developed. We continue to improve the integration of sustainability factors into investment decision making, by keeping abreast of developments in sustainable finance, the availability of sustainability data and methodologies for its analysis.

Information on the most important negative impacts on sustainability factors will be available in the periodic report!

Published: 02.04.2026