Environmental, Social and Governance Policy

Purpose

This policy explains how SUI Securities Ltd considers environmental, social and governance (ESG) matters in the way we run our firm and in the investments we choose for clients. It sits alongside our sustainability risk policy, which sets out how those risks are integrated into investment decisions.

How we run our own firm

We keep our own house in order before asking anything of others. We are a small, London-based firm, and we focus on the things we can genuinely control:

• Keeping our environmental footprint modest, including sensible use of travel, energy and paper.
• Treating clients, colleagues and suppliers fairly, and paying everyone on time.
• Clear governance: a small number of decision makers, written policies, and records that show what was decided and why.

How we consider ESG in investments

Our portfolios are built primarily on broadly spread strategies with solid reasons behind them. Where ESG matters affect the value of an investment, we want to know about them. We favour funds and index strategies whose managers apply their own systematic ESG integration and stewardship, and we consider those practices alongside price, cost, spread across different kinds of investments and how easily an investment can be sold.

Stewardship and engagement

Because we invest mainly through pooled funds, stewardship is exercised largely by the managers of those funds. We look for managers who vote their holdings, engage with companies on material issues and publish how they do it. Where we hold investments directly, we exercise voting rights ourselves and record how we have voted.

Exclusions and client preferences

We do not claim that our portfolios exclude every company connected to controversial activities, and we do not select investments solely on ESG scores. If you have specific preferences or restrictions, we take them into account in the design and ongoing management of your portfolio, and we explain how they have been applied.

What we do not promise

Considering ESG factors can reduce exposure to assets that lose value after an environmental, social or governance event, and it can also mean missing returns from assets that do well despite those risks. It is not a guarantee of better returns. The value of investments can fall as well as rise, and past performance is not indicative of future results.

Review and responsibility

A partner is responsible for this policy. It is reviewed at least annually and updated when regulation, our investment approach or our fund and supplier landscape changes materially. Anyone with a question about how ESG considerations apply to their portfolio is welcome to raise it with us directly.