No Consideration of Sustainability Adverse Impacts

Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector ("SFDR") requires Axiom Investors ICAV (the "ICAV") to determine whether it considers the principal adverse impacts of its investment decisions on sustainability factors. The ICAV is supportive of the aim of this requirement which is to improve transparency to investors and the market generally as to how to integrate the consideration of the adverse impacts of investment decisions on sustainability factors. However, the ICAV could not gather and/or measure all of the data on which it would be obliged by SFDR to report, or it could not do so systematically, consistently and at a reasonable cost to investors. This is in part because underlying companies or issuers are not widely obliged to, and overwhelmingly do not currently, report by reference to the same data. On this basis, and due to the size, nature and scale of the sub-funds of the ICAV, and in the absence of the finalised regulatory technical standards relating to this disclosure, the ICAV does not consider the principal adverse impacts of investment decisions on sustainability factors at this time. The ICAV's position on this matter will be reviewed annually by reference to market developments.

SFDR also requires the ICAV to determine and disclose whether it considers the principal adverse impacts of its investment decisions on sustainability factors at the level of each sub-fund. For the reasons set out above, the ICAV does not consider adverse impacts of investment decisions on sustainability factors at the level of each sub-fund at this time. This position will be kept under review by the ICAV.

Integration of Sustainability Risks in the Remuneration Policy

SFDR requires the ICAV to include in its remuneration policy information on how its remuneration policy is consistent with the integration of sustainability risks. Sustainability risk is defined in SFDR as "an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment". The same information (or a summary of it) must be published on the ICAV's website.

The ICAV is for the purposes of SFDR a "financial market participant". Accordingly, a sustainability risk is an environmental, social or governance event or condition which, if it occurs, could cause an actual or potential material negative impact on the value of the investments made by the sub-funds of the ICAV.

The ICAV's remuneration policy promotes sound and effective risk management and to avoid excessive risk taking and has been amended to be consistent with the integration of sustainability risks.

The revised remuneration policy is available at www.axiom-investors.com.