DISCLAIMER

Information disclaimer
The information contained in this website is for general information purposes only. The information is provided by Andreas Capital S.A. and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, services, or related graphics contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.
 
In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.
Through this website you are able to link to other websites which are not under the control of Andreas Capital S.A. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.
 
Every effort is made to keep the website up and running smoothly. However, Andreas Capital S.A. takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control.
 
Complaints
Your satisfaction is our main concern. Serving you better and improving the quality of our services are our priorities. In case you have a complaint, a specific three step process has been implemented and maximum processing times have been defined.
 
1. Your complaint has to be sent to the following address:
 
by e-mail: info@andreas-capital.com 
attn. complaints department 
or 
by mail: Andreas Capital S.A. 
attn. complaints department 

33, Boulevard Prince Henri

L-1724 Luxembourg
 
We commit to acknowledge receipt of your complaint within 10 days and answer you at the earliest with a maximum delay of 1 month.
 
2. In case your complaint is not treated to your satisfaction within 1 month please contact the authorised manager responsible for complaint escalation by registered mail:
 
Andreas Capital S.A. 
attn. Mr. Ramon Hyndycz
1, route d’Esch 
L-1470 Luxembourg
 
3. A procedure “CSSF Regulation n° 16-07 relating to the out-of-court resolution of complaints” has been put in place by the financial Supervisor (CSSF) in Luxembourg. If you and our company will not come to an agreement you might contact the CSSF . In that case we will provide you with all necessary information.
 

The position of ESG in the investment strategy of Andreas Capital S.A. (EU Regulation 2019/2088 "SFDR"):

At Andreas Capital we offer discretionary asset management mandates to our clients. In these mandates we select individual equities of companies listed and traded on stock exchanges in Europe and the United States. In our selection process we use ESG-risk factors among other variables to determine the quality and attractiveness of a listed company. Andreas Capital however does not promote to actively influence or impact improving environmental, social and governance (article 8 SFDR) when it selects listed companies for the client portfolios. Nor is the investment strategy of Andreas Capital specifically aimed at ‘green’ or ‘socially responsible investments’ (article 9 SFDR).

Incorporating ESG-risks in our selection process:

During our selection process for individual equities we use ESG-risk factors to assess and weigh the three domains Environmental (E), Social (S) and Governance (G). All three domains are scored by Bloomberg (independent financial data publisher) between 0 and 100 per company per industry sector. A score close to zero means high relative risk, a score close to 100 means low relative risk. The scores are updated annually. A score above the 50th percentile indicates that the company scores above average on that particular domain within its industry. As we wish to select only companies that are above average within their industry the aggregate score on all three domains needs to be higher than 150. Because we wish to eliminate those companies that score high on two domains but very poor on one domain, the minimum score for a single domain is 25.

We monitor the ESG-scores on a semi-annual basis. At the time of selection the ESG-criteria are met, but during the holding period in the client portfolios the score might deteriorate. If a company’s score falls below the above-mentioned minimums (<150 for aggregate score and/or <25 on one domain’s score) we will monitor the development of the score(s) to enable the company to improve its score. This monitoring period shall not exclude twelve months. Within these twelve months the position needs to be removed from the selection unless the scores  improve back above the minimum.

Remuneration policy

Andreas Capital has established a remuneration policy that is consistent with the integration of sustainability risks in accordance with Article 5 of Regulation (EU) 2019/2088.
Sustainability risks, defined as environmental, social or governance events or conditions that may have a material negative impact on the value of investments, are considered as part of the Firm’s overall risk management framework.
The remuneration policy is designed to promote sound and effective risk management and does not encourage excessive risk-taking, including with respect to sustainability risks. Where relevant, the assessment of staff performance takes into account compliance with internal policies and procedures, including those relating to the identification, assessment and management of sustainability risks.
As an Article 6 financial market participant, Andreas Capital does not promote environmental or social characteristics nor pursue sustainable investment objectives. However, sustainability risks are integrated into investment decision-making processes where relevant.