Responsible Investment

Sustainability Factors – Investment/IBIPs/Pension Advice

In accordance with the Sustainable Finance Disclosure Regulation (‘SFDR’), we inform you that when providing advice on insurance-based investment products/Investments, we do not assess, in addition to relevant financial risks, relevant sustainability risks as far as this information is available in relation the products proposed/advised on. This means that we do not assess environmental, social or governance events/conditions that, if they occur, could have a material negative impact on the value of the investment.

Considering Principal Adverse Impacts on sustainability factors in the advice:

When providing advice on insurance-based investment products (‘IBIPs’) or investment advice we do not consider the impacts of our advice that result in negative effects on sustainability factors (namely environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters), because currently there is limited relevant products on the market which meet these criteria. The area of sustainable is relatively new and as the issue progresses, we will review our position.

Neiland Financial Services will review this approach on an annual basis as we receive further improvements from the relevant life companies.

Impact on Return

We have not assessed the likely impacts of sustainability risks on the returns of Investment/Pensions since we have not been able to identify any sustainability risks that are relevant. Currently there is limited relevant products on the market which meet these criteria. The area of sustainable is relatively new and as the issue progresses, we will review our position.

Remuneration Policy

We are remunerated by commission and other payments from product producers. When assessing products, we will consider the different approach taken by product providers in terms of them integrating sustainability risks into their product offering. This will form part of our analysis for choosing a product provider.

We take due care so that our internal remuneration policy with respect to investment or insurance advice on insurance-based investment products (‘IBIPs’) promotes sound and effective risk management in relation to sustainability risks and does not encourage excessive risk‐taking with respect to sustainability risks.

We consider the adverse impacts of Investment Decisions on sustainability factors in our Investment Advice and our Insurance Based Investment Advice, both at the initial stages of our research, in our recommendation and annually as part of the investment services we provide to our clients.

As assessment of Sustainability risks are integrated into our investment advice and our Insurance Based Investment Advice through the following means:

• The Product Information provided to us by the Product Producers and the Insurers on the integration of sustainability risks
• Our professional interrogation of the information by the Products Providers and Insurers
• Our in-house Investment Research as we keep our Investment Knowledge current and relevant

This firm will review this approach on an annual basis

Remuneration Policy

When assessing products, we will consider the different approach taken by product providers in terms of them integrating sustainability risks into their product offering.  This will form part of our analysis for choosing a product provider.

We are usually renumerated by commission from the Product Producers and Insurers with whom we facilitate Investment and Insurance Based Investment transactions on your behalf. This commission payment will not influence our decision to recommend a particular product. We consider how the Product Providers and Insurers have integrated sustainability risks into their investment product offerings prior to making our recommendations to our clients