Regulatory Disclosures

Regulatory Status

Mina Asset Management Limited is authorised and regulated by the Central Bank of Ireland as an Alternative Investment Fund Manager under the European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013) as amended, and is authorised to provide certain additional investment services in accordance with Regulation 7(4) of those Regulations, including individual portfolio management, as permitted under the European Union (Markets in Financial Instruments) Regulations 2017 (S.I. No. 375 of 2017).

Sustainable Finance Disclosure Regulation (SFDR) Statements

Principal Adverse Impacts: Under Article 4 of the SFDR, we are required to disclose our policy on the consideration of principal adverse impacts (PAI) of investment decisions on sustainability factors. We do not currently consider the principal adverse impacts (PAI) of investment decisions on sustainability factors as part of our investment process due to the fact that we are not a financial market participant which is required to do so under the framework given the number of current employees. This decision is also informed by the nature of the investments held within client portfolios and the fact that the portfolios which we manage do not promote environmental or social characteristics or have a sustainable investment objective and have a sole objective of financial return. We will keep this position under periodic review.

Integration of Sustainability Risk into the Investment Decision-Making Process: Under Article 3 of the SFDR, we are required to provide information about our policies on the integration of sustainability risks into our investment decision-making process.

“Sustainability risk” is defined under the SFDR 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”. Our investment due diligence policy outlines how sustainability risk is assessed and integrated into the investment decision making processes applicable to each portfolio under management and will vary depending on the investment objectives and policies of the fund in question. This includes assessing the risk that the value of underlying investments could be materially negatively impacted by an environmental, social or governance event or condition to the extent that sufficient information exists to evaluate this sustainability risk.

For further information relating to the likely impacts of sustainability risks on the return of a particular Fund (if deemed relevant), please refer to the relevant fund supplement to the prospectus.

Remuneration and Sustainability Risks: Our remuneration policy promotes sound and effective risk management with respect to sustainability risks (defined 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 an investment), ensuring that the structure of remuneration does not encourage excessive risk-taking with respect to sustainability risks.

Under the remuneration framework, staff are not rewarded based on short-term financial performance or investment decisions that could conflict with sound risk management practices (including those relating to management of sustainability risk) or with the long-term objectives, including any sustainability objectives, of the funds or individual portfolio management mandates under management or with sound risk management practices.

Conflicts of Interest Policy Summary

At Mina Asset Management Limited, we identify, manage, and mitigate conflicts of interest between ourselves, our employees, and our clients to ensure fair treatment and protect clients’ interests. Our policies require disclosure and effective controls to prevent conflicts from adversely affecting the services we provide.

Remuneration Policy Summary

Our remuneration policy aligns with prudent risk management and supports the long-term interests of our clients. It is designed to avoid incentives for excessive risk-taking and incorporates relevant sustainability considerations proportionate to our business.

Complaints Handling

We take complaints seriously and have procedures to ensure they are addressed promptly and fairly. If you wish to make a complaint, please use the following contact details:

Mina Asset Management Limited – Attention: Complaints Officer
Watch Tower House, Blackditch, Newcastle, Co. Wicklow, A63 RF61, Ireland

We will acknowledge receipt of your complaint promptly, investigate it, and provide a substantive response in accordance with applicable regulatory requirements.

Data Protection and Privacy

We are committed to protecting your personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Irish data protection law.

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Our Privacy Notice and Cookie Notice explains: i) what personal data we collect; ii) how we use and store it; iii) your data protection rights; iv) how to contact us or our Data Protection Officer; and v) how cookies are managed and used.

The information on this website is provided for general information purposes only and does not constitute investment advice, an offer, or solicitation to buy or sell any investment product or service. Our services and funds are available only to professional investors who meet the qualifying investor criteria and who engage with us on a reverse enquiry basis.

Investments involve risk and are not suitable for all investors. Past performance is not a reliable guide to future returns. Prospective investors should refer to the relevant offering documents and seek independent professional advice before making investment decisions.

Contact Us

If you have any questions regarding the information on this page, please contact:

Mina Asset Management Limited
Watch Tower House, Blackditch, Newcastle, Co. Wicklow, A63 RF61, Ireland