On March 10, 2021, the Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial sector (the ‘Regulation’) came into force. As part of the regulation, TMF International Pensions as a Retirement Scheme Administrator (‘TMF) is required to provide certain disclosures on sustainability risks and the impact of ESG.
Sustainability risks are defined under the regulation as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.
The regulation requires TMF to disclose whether any Principal Adverse Impact (PAI) of investment decisions are considered.
All personal pension schemes administered by TMF International Pensions are member directed schemes, and as such TMF does not make or advise on investment decisions on behalf of its members. Instead, members appoint an Investment Adviser and/or an Investment Manager to advise on and manage their investments for them unless they are classified as a Professional Member, in which case they will make their own Investment decisions. Therefore, TMF does not deem the PAI of its investment decisions on sustainability factors to be relevant.
Nevertheless, the Trustees encourage investment decisions to be in line with the CSR and ESG position of TMF Group and the permitted range of investments by the Malta Financial Services Authority (‘MFSA’) and every effort will be made to ensure each member is aware of the sustainability risks relating to their investments within the Scheme.
Furthermore, the Company has a fixed remuneration policy, save for instances following a performance review both at Company and personal level. For this reason, TMF believes its remuneration policy falls in line with the integration of sustainability risks.
As part of TMF Group, the Trustees adopt a corporate culture aligned with the permitted range of investments by the MFSA and TMF Group’s Group Corporate Social Responsibility (CSR) and Environmental, Social and Governance (ESG) position. Details of the TMF Group policy can be found at: