Disclosures
Sustainable Finance Disclosure Regulation Disclosure
M.Z. Investment Services Limited (the “Company”) is an investment services firm that for the purposes of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector, acts as both a Financial Market Participant (“FMP”) in the context of its portfolio management services, and as a Financial Adviser (“FA”) when providing investment advice..
Integration of Sustainability Risks
At present, the Company does not integrate Environmental, Social and Governance (“ESG”) factors or sustainability risks in its investment decision-making or investment advice processes. The Company considers that ESG factors do not form part of its investment or advisory methodology and therefore do not influence the investment decisions or recommendations provided to clients.
This approach reflects the Company’s current investment philosophy and the view that sufficient, consistent and comparable data to assess the likely impacts of ESG factors on the long-terms financial performance of financial instruments is not reliably available across the wide and diverse range of instruments it distributes re recommends.
No Consideration of Principal Adverse Impacts (PAIs)
In accordance with Article 4(1)(b) and Article 4(5)(b) of SFDR, the Company hereby states that it does not undertake an assessment of the principal adverse impacts (“PAIs”) of its decisions on ESG factors. PAIs are those impacts arising from a particular decision taken or investment recommendation made that will eventually have a negative effect of ESG factors.
Given the Company’s investment strategy, the range of financial instruments considered (which include instruments where ESG data is not consistently or comparably available), and the current lack of reliable and accessible data across asset classes, the Company is of the view that it is not feasible at this stage to perform a meaningful and systematic assessment of PAIs.
The Company may revisit its position in the future in light of regulatory developments, data availability, or changes in its investment approach.
ESG Policy and Suitability Assessment
While the Company does not integrate ESG risks or assess PAIs, it maintains an internal ESG Policy to reflect its stance on sustainability-related matters and compliance with applicable regulatory requirements.
In line with MiFID II requirements, when providing investment advice or portfolio management services, the Company conducts a suitability assessment, which includes an evaluation of the client’s sustainability preferences. Where clients express a preference for sustainable investments, the Company takes these preferences into account when selecting or recommending suitable financial instruments.
Investment Committee and Financial Instrument Selection
The Company has established an Investment Committee responsible for determining the range of financial instruments distributed or recommended by the firm, as well as the associated distribution strategy.
Financial instruments are selected based on a range of factors, including their nature and complexity, and any available financial and non-financial information. However, the absence of reliable ESG data across many instruments remains a challenge to integrating sustainability considerations in a comprehensive and consistent manner.
Ongoing Review
The Company continues to monitor the regulatory landscape and industry practices regarding sustainability disclosures and ESG integration. It will review and, where appropriate, update this disclosure in line with further developments in legislation and market standards.
Remuneration Policy Disclosure under SFDR
At present the Company does not integrate ESG risks or sustainability risks into its investment decision-making or advisory processes. As such, sustainability risks are not a factor in the determination of variable or fixed remuneration for employees involved in portfolio management, investment advice or other relevant activities.
The Company’s remuneration structure is designed to ensure that decisions are made in the best interests of clients, in line with regulatory obligations, and to avoid conflicts of interest. It aligns with the Company’s risk profile and business strategy and is not based on the promotion or consideration of ESG characteristics.
The Company will continue to monitor regulatory developments and will review and update this disclosure as necessary in the event of changes to its investment or remuneration practices.
What is a Complaint?
A complaint is an expression of dissatisfaction or concern about a particular issue, situation, products, service or behaviour. Complaints can arise when expectations are not met, and they often highlight perceived problems or shortcomings that need attention or resolution.
How to file a complaint
In the circumstance where a client may wish to file a complaint the client may inform his/her usual contact at MZ Investments in person, in writing, by email or by telephone. Alternatively, the client may file a complaint directly with the Company’s Compliance Officer or through this website by completing and submitting a complaint form.
The Company’s Compliance Officer will deal with your complaint reasonably and promptly and in accordance with the Company’s complaint handling procedures. Details of the MZ Investments complaint handling procedures are available upon request.
The Company will try to resolve the complaint as quickly as possible and to your complete satisfaction within 15 working days from receipt of the complaint.
However if MZ Investments is unable to assist you further or if you are not satisfied with the manner in which your complaint has been handled by the Company, you may refer your complaint to: The Office of the Arbiter for Financial Services. The contact details for the latter are provided below:
Office of the Arbiter for Financial Services
First Floor,
Pjazza San Kalċidonju,
Floriana FRN 1530, Malta.
Further information may be obtained through the official website: www.financialarbiter.org.mt and/or freephone (local calls): 8007 2366 and telephone: (+356) 2124 9245.
The Company’s latest Terms of Business can be viewed here.