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ESG Policy

Eisler Capital Malta Ltd (“ECML”) in accordance with EU/2019/2088 (Regulation on sustainability disclosure in the financial services sector - SFDR) is required to publish information on its websites on:

  1. the integration of sustainability risks into the investment decision-making process (including Environmental, Social or Governance ("ESG") risks, as well as climate change and biodiversity risks).
  2. the main adverse effects of investment decisions on ESG factors; and
  3. how their remuneration policies are compatible with the integration of ESG risks (this information must also be provided in companies' remuneration policies).

At product level, ECML is required to disclose.

  1. information in pre-contractual documents provided to investors, and in periodic reports, on how ESG risks are integrated into managers' investment decisions, and the likely impact of these risks on the returns of the financial instrument; and
  2. information in pre-contractual documents provided to investors, and in periodic reports, on whether the financial instrument integrates negative impacts on ESG factors.

This publication is made solely for the benefit of ECML’s clients, Eisler Capital UK Ltd, the Eisler Capital Multi-Strategy Master Fund and Eisler Capital Opportunity Master Fund.

The Eisler Group's 1 investment strategies for the Eisler Capital Funds 2 do not have a specific sustainability investment objective and therefore do not prioritize environmental or social characteristics under the SFDR. As with the Group as a whole, ECML employs a wide variety of investment strategies, and the relevant sustainability/ESG considerations vary according to these different strategies and the investment approaches of the different portfolio managers, noting that portfolio managers are expected to consider all relevant material factors when implementing their management strategy. As a result, ECML does not incorporate a centralized ESG approach as part of its multi-strategy model, but PMs may consider these factors.

The SFDR regulation also requires ECML to disclose whether, and - if so - how, it considers the main negative impacts of its investment decisions on sustainability factors. At present, ECML does not consider the main negative impacts of its investment decisions on sustainability factors, as the management strategies to which ECML has been appointed do not provide for the consideration of such impacts.

For the reasons provided above, ECML also does not consider sustainability risks or the main negative impacts on sustainability factors in its compensation system.

1 The term "Eisler Group" means Eisler Capital UK Ltd, its affiliated management companies and any related entities, and each entity identified as a sub-advisor within the offering documents of the Eisler Capital Funds.
2 Eisler Capital Multi-Strategy Master Fund Ltd and the Eisler Capital Opportunity Master Fund SPC their affiliated feeder funds and wholly owned subsidiaries, if any.